ML20129D877

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Insp Rept 50-423/85-04 on 850219-0301 & 0311-22. Const Deficiencies Noted:Physical Separation of Installations Not Maintained
ML20129D877
Person / Time
Site: Millstone Dominion icon.png
Issue date: 04/26/1985
From: Chan T, Heishman R, Phillips H, Reynolds S, Rohrbacher R, Saunders A, Wheeler R, Wong H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20129D868 List:
References
50-423-85-04, 50-423-85-4, NUDOCS 8506060254
Download: ML20129D877 (100)


See also: IR 05000219/2003001

Text

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                        UNITED STATES NUCLEAR REGULATORY C0Pt11SSION
                            OFFICE OF INSPECTION AND ENFORCEMENT
                                 DIVISION OF INSPECTION PROGRAMS
                            REACTOR CONSTRUCTION PROGRAMS BRANCH
      Report No.:-         50-423/85-04
      Docket No.:          50-423
    ' Licensee:            Northeast Nuclear Energy Company
      Facility Name:       Millstone Nuclear Power Station, Unit 3
      Inspection At:       Waterford, Connecticut
      Inspection Conducted:        February 19-March 1 and March 11-22, 1985
      Inspectors:     ,
                                            #     -
                                                                                   k[
                   sH. J. Wo       ,)r. Reactor Construction Engineer           Date Signed
                     Team L d
                                  ./                                             4f26fW
                     T. (L. Chan, Reactor Construction Engineer                 Date Signed
                      $M 6,(WW                                                   V/wrr
                     H( W. Phil       ps, Rdactor Cofistruction Engineer        Date Signed
                      .Wh w 4h & & A-                                            V/La/s{
                     S. D. Reyflolds, Lead Redctor Engineer (Region I)          Date Signed
                        }f $"                                                    n u-rr
                                             Sr. Reactor Construction Engineer Date Signed
                     R. A. Rohrbache)rOlkM. aw Date'
                     A. H. Saunders, Reactor Construction Engineer
                                                                                  JJu Signed ;
                               W ffr                                              bWW
                                                                                 Date Signed
                                                                                               '
                     R.' M. Wheefer, R6sident ' Inspector (Region I)
                     Consultants:       R. M. Compton, D. C. Ford, J. B. McCormack,
                                        0. P. Mallon, W. S. Marini, E. Y. Martindale,
                                        R. E. Serb and W. J. Sperko, Jr.
      Approved By:    [        -           <
                     Robert F. Heishman, Chief
                                                                                  IJ[[h
                                                                                 Date Signed
                     Reactor Construction Programs Branch
 8506060254 850521
 gDR ADOCK0500g4y3

.

          _ _ _ -        _ _ _ _ _ ..         ___ ______      -   _ _ . _   ___ _____ _ _ _ _

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                                                                                              .
                                                                                                                                                i
                                                                          ' TABLE OF CONTENTS
    . -
                         ; TOPIC.                                                                                                     SECTION   ,
                                                                                                                                                !
                             ' INSPECTION SCOPE AND OBJECTIVES ....................................                                        I-
                                            .
                                                         .   .
                                                                                                                                                ,
                                  ELECTRICAL-AND INSTRUMENTATION C0NSTRUCTION'........................                                    II
                                MECHANICAL' CONSTRUCTION .............................. .............                                   III
      ,
                         - WELDING AND NONDESTRUCTIVE EXAMINATION .............................                                         'IV
                          - CIVIL AND STRUCTURAL CONSTRUCTION ..................................                                          'V
                          . M TERI AL TRACEABILITY ' AND CONTROL 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    VI
                                DESIGN' CHANGE CONTROL ..............................................                                   VII.
.
                    ,
                      , :       CORRECTIVE = ACTION SYSTEMS ..........................................                                 VIII
                               ATTACHMENT A.- PERSONS CONTACTED AND DOCUMENTS REVIEWED

"

                        - ATTACHMENT B - GLOSSARY OF ABBREVIATIONS                                                                              ;
                                                           *
                  -
      "
                                      _s,
             ,-
                                                                m
                                                                                                                                              9

I w M. _ m

 ,                                                                                -
   I. INSPECTION SCOPE AND OBJECTIVES
      The objective of this inspection was to evaluate the adequacy of construc-
      tion at the Millstone Nuclear Power Station, Unit 3. This objective was
      accomplished through review of the construction program, evaluation of
      project construction controls, and review of selected portions of the
      Quality Assurance Program, with emphasis on the installed hardware in the
      field. In addition, the scope and significance of identified problems were
      determined.
      Within the areas examined, the. inspection consisted of a detailed examina-
      tion of selected hardware subsequent to quality control inspections, a
      selective examination of procedures and representative reccrds, and limited
      observation of in process work.
      For each.of the areas inspected, the following was determined:
          Were project construction controls adequate to assure quality
          construction?
          War the hardware or product fabricated or installed as designed?
          Were quality verifications performed during the work process with
          applicable hold points?
          Was there adequate documentation to determine the acceptability of
           installed hardware or product?
          Are systems turned over to the startup organization in operable
          condition and are they being properly maintained?

,

                                         I-1

II. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION

   A. Objective
      The primary objective of the appraisal of electrical and instrumentation
      construction was to determine whether components and systems were
      installed in accordance with regulatory requirements, Safety Analysis
      Report (SAR) commitments and approved vendor and construction specifi-
      cations and drawings. Additional objectives were to determine whether
      procedures, instructions and drawings used to accomplish construction
      activities were adequate and whether quality-related records accurately
      reflect the completed work.
   B. Discussion
      Within the broad categories of electrical and instrumentation construc-
      tion, attention was given to several specific areas. These included
      electric cable, raceways, raceway supports, electrical equipment, and
      instrumentation components. Additionally, a review was made of a
      selected number of documents associated with design change control and
      nonconformance reporting.
      A number of documents were generated by the licensee and Stone & Webster
      Engineering Corporation (SWEC) as a result of observations made by the
      NRC Construction Appraisal Team (CAT) inspectors during electrical and
      instrumentation inspection.     Several are referenced in this report and
      are listed in Table II-1.
      1.    Electrical Raceway Installation
      a.    Inspection Scope
            Fifty-two segments of installed Class 1E cable tray, representing a
            total length of about 1,300 feet, were selected from various plant
            areas for detailed examination by the NRC CAT. These segments were
            inspected for comp iance to requirements relative to routing,
            location, separation, support spacing and configuration, identifi-
            cation, protection and physical loading. Additionally, 24 runs of
            installed conduit, with an aggregate length of about 1,200 feet,
            were inspected for compliance to specified requirements such as
            routing, location, separation, bend radii, support spacing and
            associated fittings.
            A sample of nine raceways (five conduits and four cable tray sec-
            tions) were selected by the NRC CAT inspectors for comparison of
            the actual quantity of cables installed with the quantity specified
            to be prasent by the SWEC computerized system of scheduling and
            routing cables, known as the "ECSIS Program."
            Over 20 raceway supports were examined in detail for such items as
            location, material, type, size, anchor spacing, weld quality, bolt
            torque and installed configuration.
                                       II-l
     _ _ _ .
                  ,
                      Fifty-tso concrete expansion anchors associated with Seismic
                      Category I conduit supports were inspected in detail for compliance
                      with requirements relating to embedded depth,' plumbness, spacing and
                      thread engagement. The anchors selected were of various sizes and
                      from--several locations in the facility.    A calibrated torque wrench ,
   +
                     was used to determine whether appropriate torque had been applied
                      during installation to ensure proper setting of the wedges, and
                      ultrasonic test equipment was used to determine embedded depth.
                      See Table II-2 for a listing of cable tray, conduit, concrete
                      anchors and raceway support samples.
                     The following_ documents provided the basic acceptance criteria for
                      the. inspection:
 ^
                    -*
                             SWEC Quality Control Instruction FM3-D10.18-01B, " Seismic
                            Conduit Support, Conduit and Cable Tray Installation."
                            SWEC Quality Control Instruction FM3-D10.18-02A, " Cable Tray
                            and Support Installation."
                            SWEC Quality Control Instruction FM3-D10.18-040, " Raceway
                            and Cable Separation Inspection."
                            SWEC Quality Control Instruction FM3-D10.18-030, "Non-Seismic
                            Field Run Conduit Inspections."
                     *
                            SWEC Field Construction Procedure 299, " Installation of
                            Drilled-In Expansion Type Concrete Anchors," Rev. 1
                            SWEC Specification M924, " Drilled-In Expansion Type Concrete
                            Anchors
                            SWEC Specification 2400.000-350, " Electrical Installation,"
                            Rev. 7.
               b.    Inspection Findings
                     In the area of electrical. raceway, the NPC CAT inspectors observed
             ,       that, in general, Class 1E raceway installations were in accordance
                    with applicable design criteria. Important quality attributes such
                     as material type, location,' identification' and installed configu-
                     ration were found to be as shown on approved construction drawings.
                    However, several construction deficiencies were identified and are
                    discussed below.
                                                           '
                     (1) Raceway Separation
                            The Millstone Unit 3 Final Safety Analysis Report (FSAR)
                            Section 8.3.1.4 " Physical Independence of Redundant Systems"
                            provides the basic criteria for acceptable raceway and cable
                            installations. This section describes requirements for
                            physical arrangement of raceways pertaining to the requirements

F of Regulatory Guide (RG) 1.75 for independence of redundant

                            systems.
                                                  II-2

,

     In general, .these FSAR criteria specify the phy ical separation
    that must be maintained between components of redundant elec-
    trical' divisions.   Additionally, separation is required between
    components performing Class 1E and Non-Class 1E functions.
    The NRC CAT examination of the selected raceway sample
    disclosed numerous installations where the required physical
    separation had not been maintained. Many of the identified
    discrepancies were observed between Class 1E and Non-Class 1E
    raceway components.
    These deficiencies were discussed with the licensee and SWEC
    personnel. The discussions disclosed that~in a number of areas
    the licensee recently has elected to reassess currer.t commit-
    ments to RG 1.75 and establish.through test and analysis that
    lesser degrees.of physical separaticn are acceptable. Justifi-
    cation for this approach is detailed in Section 5.1.1.2 of IEEE
    Standard 384-1974 which states..."In those areas where the
    damage potential is limited to failures or faults internal to
    the electrical equipment.or circuits, the minimum separation
    distance can be established by analysis...."
    In connection with physical separation criteria, the NRC CAT
    inspectors reviewed Engineering Service Scope of Work (ESS0W)
    No. 2412.000-732. This document established the testing
    required to demonstrate the acceptability of lesser separation
    and the use of barriers in lieu of distance to meat physical
    separation requirements. In general, the objective of the
    test was to demonstrate that a single enclosure is adequate
    between Class 1E and Non-Class 1E cable. Additionally, for
    cable dropouts and perpendicular raceway crossings, a spatial
    distance of one inch is acceptable instead of the six inches
    currently rcquired. Several other criteria changes would be
    implemented based upon successful completion of the test
    program.    In some installations, one barrier would be used
    instead of the two currently required and for certain conduit
    installations a minimum of 0.125 inch spatial separation would
    be allowed. Copies of this document have been provided to the
    NRC Office of Nuclear Reactor Regulation (NRR) for licensing
    review.
    NRC CAT inspectors also reviewed Engineering Design Coordina-
    tien Report (E&DCR) FE-40530 which was issued to implement
    separation criteria changes to the electrical specification
    based upon preliminary test results provided by Wyle Labora-
    tories. In effect this E&DCR permits many of the separation
    deficiencies observed by tha NRC CAT inspectors. However, this
    design change is not consistent with current FSAR requirements-
    and thus the status of this issue is considered open pending
    NRR review of test results and applicable FSAR changes. NRC
    Region I is aware of this situation and their review of this
    matter is continuing.
~
                          II-3

m _

r

           In connection with this issue NRC CAT inspectors also noted
           that a program to identify and physically tag raceway and -
   ~
          cable components requiring installation of fire barriers had
           been-implemented by SWEC personnel. A review of this program
           indicates that sufficient procedural controls exist to assure
           that required barriers will be installed and inspected.
     (2) Electrical Conduit
          The conduit sample. inspected conformed to applicable design
          and installation requirements relative to such attributes as
          size, routing, identification and. supports. Conformance to
          separation requirements are discussed in Section II.B.1.b.(1),

,

          Raceway Separation, above.
     (3) Raceway Supports
          The examination of raceway supports was accomplished for both
          conduit and cable tray applications. In general, attributes
          such as location, material type and size, anchor spacing,
          welds (location, size and general quality), and installed
          configuration were found to be in accordance with design
          requirements. No construction deficiencies were identified in
          this area.
     (4) Concrete Anchors
          In the area of concrete expansion anchor installation, most of
          the anchors inspected were properly installed. However, two
          isolated discrepancies were identified. Concrete spalling was
          observed in the vicinity of the lower right anchor behind the
          attachment plate of conduit support CS-550. As a result of
          this observation, SWEC QA Inspection Report ESA0 1210 and
          Nonconformance and Disposition Report (N&D) 11542 were issued
          to document and disposition this matter. The second
          discrepancy pertained to anchor location. The top anchor in
          conduit support ES-1227 was one and three-fourths inches from
          an embedded plate. Specification 2199.142-924 requires a
          n.inimum of six inches from a half-inch anchor to an embedded
          plate. As.a result of this finding, Inspection Report E5A01873
          was issued to document this condition.
     (5) Raceway Fill
          Of the nine raceways selected to determine whether the speci-
          fled number of cables matched those actually installed, eight
          raceways contained the quantity specified by the computerized
          program (ECSIS) used to schedule and route cables. In one
          raceway, cable tray 3TC4100, 154 cables were physically in the
          tray, but ECSIS could account for only 150. In order to
          reconcile this difference it was necessary for the SWEC Site
          Engineering Group (SEG) to review additional information not
          presently contained within ECSIS. This additional information
          was in the form of " Advance Cable Pull Tickets." An Advance
          Cable Pull Ticket is one manually generated by SEG, issued to
                                II-4
 .
 .                                     .                .              . -
                construction for installation, and incorporated into ECSIS at a
                later~date. Although a rather lengthy review of many unincor-
                porated. Advance Cable Pull-Tickets were involved, the installed
                quantity of 154 cables in tray 3TC4100 was justified. However,
               -it should be noted that the full intent of the ECSIS program to
              , schedule and route cables cannot always be accomplished pro-
                perly when.many (currently about 300) Advance Cable Pull
                Tickets are not incorporated into the ECSIS program in a timely
                manner.    It was noted that the Advance Cable Pull Ticket for
                cable 3MSSAOC043 had been in existence since May 1983 without
                being incorporated into the ECSIS program.
   c.    Conclusions
         Except as noted, raceway systems have been installed in accordance
         with applicable design and installation requirements.
         Physical separation criteria detailed in the licensee's FSAR have
         not been maintained in many raceway installations. However, pre-
         liminary discussions with NRR and the results of testing indicate
         that lesser separation may be acceptable. This matter remains open
         pending NRC final review and evaluation.

,

   2.    Electric Cable Installation

.

   a.    Inspection Scope
         The NRC CAT inspectors selected a sample of installed Class 1E cable
         runs that had been previously accepted by SWEC Field Quality Control
         (FQC). inspectors. The sample included high voltage, power, control
         and instrumentation cables. For each of the cable runs, physical
         inspection was made to ascertain compliance with applicable design
      . criteria relative to size, type, location / routing, bend radii,
         protection, separation, identification and support.
         Additionally, the NRC CAT inspectors selected approximately 400 cable
         ends for examination. These were inspected to applicable design and
         installation documents for items such as lug size and type, proper
      . terminal point configuration, correct identification of cable and
         conductors, proper crimping of lugs or connectors and absence of
         insulation or jacket damage. Jee Table II-3 for a listing of cable
         terminations examined.
         The following high voltage and power cables, totaling about 1,600
         feet, were selected from different systems, electrical trains and
         locations:
                     Cable                             Type
               3SIHBPH350                         3 conductor 4 AWG 4.16KV
               3RHSA0H350                         3 conductor 4 AWG 4.16KV
               3EJBA0K610                         2 conductor 8 AWG 125V DC
               3HVCA0K075                         3 conductor 12 AWG 480V
               3RHSN0K001                         3 conductor 12 AWG 480V
               3SIHN0K095                         3 conductor 12 AWG 480V
                                      II-5
      --          .-                .      .   -     -      -       _
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                                                                                                   '

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   o  *
                   IThe[followingcontrolcables,totalingapproximately1,100 feet',were.
                    selected from different systems,.. electrical-trains and-locations:
    ,
                         _           . Cable'                             Type
            -
                                 i3EGPBPG455                         4 conductor 12 AWG 120V

,

                                  3ENSAOC453                        '2 conductor.14 AWG 120V
              1=                  3GSNN00602-                        2 conductor-14'AWG 125V.DC
                                 .3RCSAPC702                         2 conductor 14 AWG:125V-DC
                                 L3RHSAOC034                        -2 conductor.12 AWG'120V
                                 '3RHSAPC910.                        5 conductor 10 AWG 125V DC
                                  3SIHAOC005.                        7 conductor 12 AWG 120V
                                  3SIMBPC010-                        7 conductor 10 AWG 120V
          ,
                 ~The.following-instrument cables,. totaling approximately:1,200 feet, were
                    selected from different-systems, electrical trains and locations:
                                      Cable                               Type
    .
                                  3NMIA0X800                         2 conductor 16 AWG
                                  3RPSA0X821                         2 conductor.16 AWG
                                  3RPSBPX800                         2 conductor 16 AWG
                                  3SIHA0X830                         2 conductor 16 AWG

,. '

                                 -3SIL2PX802'                        16 Tw/ pair 18.AWG
                                  3SIL10X802                         16LTw/ pair 18 AWG
                    The following documents ~provided the basic acceptance criteria for the
                    inspection:

I

                    *
                            SWEC Quality A' ssurance Directive QAD-10.18ML, " Raceway and Cable :
                            Installation Inspections," Rev. 0
                    *
                           .SWEC Quality Assurance Directive QAD-10.17ML, " Cable Termination -
                           ;and Connection Inspections," Rev. B

. , r

                 1':
                           .SWEC Quality Control Instruction FM3-D10.18-03A, " Raceway and Cable
                            Separation-Inspection"

" *

                           >SWEC Field Construction Procedure 330, " Installation of Cable In
        ~
                 -
                            Ducts, Conduits or Trays," Rev. 1
                    *
                            Northeast Nuclear Energy Co., Millstone Unit'3, "Startup Manual,"
                            Rev. 3

l- b. . Inspection Findings L- .(1)' Routing

                                  In' general, the routing of Class 1E cables through design
                                  designated raceway systems was found to be in accordance with
. specified criteria. A discrepancy was noted in the routing of

[ '

                                  cable 3HVCAOK075.   The pull ticket issued for this cable shows
                                  a "From" destination of cubicle 3M in Motor Control Center

i 3EHS*MCC1A2. However, the actual routing of the cable is to.

                                  cubicle 2H of the same Motor Control Center.

D

                                                        II-6

o

                        -                              _              ,
                 Discussions with SWEC engineering personnel disclosed that the
                 cubicle information shown on the cable pull ticket was an
                 " optional entry" and that the cable had been installed
                 correctly in accordance with the applicable conductor
                 termination sheet.
                 No further discrepancies were observed in this area.
                                          .
           (2) Separation
                                  ~
                The'-inspection of Class 1E cable installations revealed a
                number of instances in which electrical separation criteria
                had not been maintained.     Examples included Class 1E cable
                 installations which did not maintain adequate spatial
               . separation between redundant divisional cables, from Non-Class
                1E cabling or from electrical raceways containing cabling of
                other divisioks. Discrepancies were observed in a number of
                 locations, but these discrepancies were most prominent in the
                Cable Spreading Room and in areas where cables exit design

'

                designated raceways and run free-air.
                Although these installations were not in compliance with -
                requirements detailed in Section 8.3 of the Millstone Unit 3
                FSAR, discussions with the licensee indicate that alternate
                criteria have been developed and are being evaluated. A
                detailed discussion of this issue is presented in Section
                II.B.1.b of this report.
                Section 8.3.1.4.2.18 of the FSAR specifies the minimum separa-
                tion distance required for cables located inside control panels
                and cabinets. During examination of the Main Control Boards,
                the NRC CAT inspectors identified extensive wiring separation
                          -
                discrepancies not meeting the above requirements. The discre-
                pancies observed involved redundant Class 1E wiring which had
                been installed by the vendor or modified by design or construc-
                tion activity. Over 70 separation deficiencies were identi-
                fied, of these more than 20 were installations in which
                redundant Class 1E wiring or wire bundles were in physical
                contact with each other. Although a detailed examination was
                not performed, a number of separation discrepancies involving
                Non-Class 1E wiring were also identified.
                NRC CAT inspectors reviewed applicable inspection procedures
                to determine whether the procedures had incorporated adequate
                attributes for inspection of vendor or modified vendor wiring
                separation in these panels. Project Procedure NEAM 128,
                " Inspection of Separation," Rev. 1, was also reviewed. NRC CAT
                inspectors noted that these documents provided for inspection
                of field installed cables and wiring, but did not specify
                inspection of vendor installed components.    Therefore, it was
                determined that sufficient procedural controls did not exist to
                assure that wiring separation discrepancies in the Main Control
                Boards would be identified and corrected.
                                      II-7
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                                                                                                                                                                                                                                    .
       .
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                                                                                                                                                                                                                                    ,
                                                                                                                                         ~
      ,
                                                  As a result of this. observation the: licensee has : issued a.
                                                  Change Notice to include the.following requirement.in Project
                                              "
                                                  Procedure NEAM 128: " Included in this inspection would be any
    .
   "*                                             vendor wiring that may have:been affected-by field modifica-
                                                   tion." : Additionally,-E&DCR FE-41807 has been issued to assure                                                                                                                   L
                                                  a 100% inspection of wiring in this-equipment.~
                                                   In general, separation ~of cables'and wiring in other' electrical
                                                  equipment and panels was found to be in accordance with FSAR
                                                  requirements. -Where discrepancies did exist they had been
                                                  documented by inspection' personnel.
                                                                                                                                                                                                                                    t
                               (3)~ Cable Spacing
                                                  Power cable installations have been designed in accordance
                                              - with ICEA Publication' P-46-426 " Power Cable Ampacities." The                                                                                                                      ,
                                            - Millstone Unit 3 FSAR Table 8.3-2 details a minimum spacing
                                                 requirement;for power cables installed in cable trays based on
        -
                                              - rated voltage and applicable derating. In general, this
                                                 spacing between adjacent cables is equivalent to one' quarter of                                                                                                                   '
 ,                                               the sum of the overall cable diameters.
                                                 NRC' CAT-inspectors identified several power cable installations
                                                  in which.the requirement for spacing had not been met. The
                                                 following cable trays contained cables which exhibited this
                                                 condition:                                                                                                                                                                         *
                                                                                            3TH4000
                                                                                            3TH304P
                                                                                            3TH103P-
                                                As a result of this observation, SWEC inspection personnel                                                                                                                          '
                                                 have issued Inspection Reports ESA01331, ESA01335 and ESA0348
                                                to document and correct this condition.
                                                                                                                                                                                                                                    .
                              '(4) Cable Identification
                                                One: example was identified'in which a Class 1E cable had not
                                                been properly color coded. Most Class 1E cables have color .
                                            '
                                                                                                                                                                                                                                    i
                                                coded jackets.which match the divisional color coding to which
                                                they are assigned. Class 1E cables _ manufactured-with black
                                                 insulation jackets are color coded every 15 feet with adhesive
                                                markers.          NRC CAT inspectors identified type NHT-40 cables run
                                                 in Electrical Man Hole 38 for a distance of about 25-30 feet                                                                                                                       i
                                                without the required color coding for Class 1E Division "A"
                                                cables.
                                                As a result of this observation, SWEC inspection personnel have

' ~

                                                 issued Inspection Report ESA01325 to document and correct this
                                                condition. No other deficiencies were identified relative to
                                                 identification of cables.

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                                                                                                  II-8
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       In general, the identification of Class 1E cable installations
      was found to be in accordance with criteria specified in the
      Millstone Unit 3 FSAR. It was noted, however, that color
      coding of Class 1E cables every 15-feet, as stated in the
      FSAR; does not conform to RG 1.75, " Physical Independence of
      Electric Systems," Regulatory Position 10, which states in
      part "...at   intervals not to exceed 5 feet throughout the
      entire cable length." Current cable identification practices
      are to be reviewed by NRR as discussed in Section 8.3.3.2 of
      NUREG-1031, " Safety Evaluation Report, Millstone Unit 3,"
      dated July 1984. NRC Region I is aware of this matter.
 (5) Tray Fill
                                                                      :
      The Millstone FSAR Section 8.3 sets forth requirements for
      limiting tray fill to the top of the side rails of the tray.
      NRC CAT inspectors identified no significant discrepancies in
      this area.
 (6) Terminations
      In general, cable termination activities, as performed by
      construction personnel, conformed to requirements. However,
      several instances of inadequate design coordination and post
      turnover wiring discrepancies were observed.      These
      discrepancies are detailed in Table II-4.
      Eight discrepancies relate to incomplete implementation of
      engineering changes required to revise termination configu-
      ration. Generally, SWEC/SEG made the necessary drawing revi-
      sions when termination changes were required but failed to
      issue corresponding revised termination tickets. Revised
      termination tickets are the only approved documents used to
      initiate physical termination changes and subsequent inspec-
      tions. Additionally, it was not readily evident or clear what
      methods have been established to assure that termination
      tickets are generated for all required terrination changes.
      Seven discrepancies relate ta post-turnover wiring changes.
      The Millstone Unit 3 Startup Manual requires wiring changes and
      discrepancies to be documented upon discovery. For this group
      of discrepancies, the licensee indicated that documentation
      would be provided later - upon completion of testing rather
      than when found. This is not in accordance with Section 5 of
      the Startup Manual.
 (7) Bend Radius
      During the examination of Class 1E Motor Control Centers
      (MCCs), NRC CAT inspectors identified several vendor leads
      within MCC starter cubicles which violate requirements for
      minimum bend radius. As an example, the lead from the motor
      starter to phase T-1 of the bus bar in MCC 3EHS*MCC3A2 has a
      bend radius requirement of 1.4 inches. The installed
      configuration of this lead resulted in a bend radius of only
                            II-9
  -                        <
  T              -
                     '
                             _                                                             _
                         _                          ,
    5 . D }~             (
                                             10.6Linchl LAs a result of this observation, SWEC. inspection
            + ~                            , personnel initiated an inspection of vendor leads.
                                           fThe-following'_ list. identifies ~MCCs in which additional bend
 /
                               '
                                                                _
                                               - radius = discrepancies were found:
                       '
                                  .
                                                                   -3EHS*MCC3Al-F5H
                                 -'
                                                                    3EHS*MCC381-R6F
                                                                    3EHS*MCCIA2-3F
               '.                                                   3EHS*MCC182-3F
                                         ,
                                                                    3EHS*MCC1B1-4Fo
                                                                     ~
                                                As. a result of these observations, SWEC inspection personnel
                                               'havefissued N&Ds 11,936 and 11,932.
                                                Bend radius discrepancies were also identified in two field
             -
                                                installed cables. . Cable 3CESAOC355, located in cubicle 311 of
                                           ~
                                                4.16kv Switchgear 3 ENS *SWGA,.and cable-3ENSBPC398, located in
                                                cubicle 413 of'Switchgear-3 ENS *SWGB, exhibited unacceptable    ..
                                                bend radii. - As'a result of:these observations, SWEC inspection
                                                personnel issued N&D reports 11,922 and 11,923 to document and
                                                correct this condition.
                                               -The instances'of bend radius discrepancies in field installed
                                                cabling are considered isolated because other cables examined
                                             -
                                                had been installed properly. _ Regarding discrepancies _ in
                                                vendor wiring, further licensee attention will be required to
    1
                                                assure that these components are properly installed.
                                    -(8) Receipt of Allegation
                                                During inspection of electrical cable-insta11ations, NRC CAT'
                                                inspectors received an allegation pertaining ~,to-installation
                                                records.    The alleger was informed that the NRC Resident
                                                Inspector would contact him and investigate his' concerns.
                                                                                                       ~

,-

                                                                                                                    _
                                 c.  Conclusions
                                     In general, cable installation including terminations _have been
                                    accomplished in accordance with requirements.             However, extensive
                                    wiring separation discrepancies exist in the Main Control Boards.
                                     Further' licensee attention is required to assure that these
           2
                                    discrepancies are properly identified and corrected.
                   '
                                    Some aspects of vendor installed wiring in motor control centers
                                    will require additional inspection and evaluation.
                                    One group of termination discrepancies were identified that were                  c
                                    due to inadequate control of termination revisions. Revised
                                    termination tickets were not issued so that required work could be
                                    accomplished.
                                    Another group of termination discrepancies related to post-turnover
                                    activities.          Some post-turnover wiring changes were not recorded as
                                    required by the Millstone Unit 3 Startup Manual.            Additional
                                                                       II-10
                                                                                                 .
  ^

L:

          management-attention is necessary in the area'of procedural controls
          to assure that. final wiring configurations are in accordance with
          design requirements and are properly documented.
      -3. Electrical Equipment Installation.
       a.  Inspection' Scope
          Over 35 pieces of installed electrical equipment and associated
          hardware items were inspected.        Samples were based on system func-
          tion and safety classification.
          .The following specific electrical components were inspected in
          detail:
          (1) Motors
                The installation of five motors and associated hardware was
                inspected for such items as location, anchoring, grounding,
                identification and protection.       The motors inspected were:
                     Safety Injection Pump Motor          3SIH*P1A
                     Safety Injection Pump Motor          3SIH*P1B
                     Residual Heat Removal Pump           3RHS*P1A
                       Motor
                     Charging Pump Motor                  3CHS*P1B
                     Component Cooling Pump Motor         3CCP*P1C
          (2) -Electrical Penetration Assemblies
                The following containment penetration assemblies were
                inspected:
                     3RCP*E6V             480V Power
                     3RCP*E4V             480V Power
                     3RCP*F8V             Control
                     3RCP*FlV             Instrumentation
                     3RCP*F3V             Control
                The location, type, mounting and identification of these
    ,
                penetrations were compared with the installation drawings and
                vendor manual.
          (3) Circuit Breakers
                Circuit breakers for the following Class 1E motors were
                examined to determine compliance with design and installation
                documents for size, type, system interface and maintenance.
                              Emergency Service Water Pump Motor
                              Safety Injection Pump Motor
                The use of circuit breakers with integral undervoltage trip
                attachments was also investigated.
                                       II-11
 (4) Switchgear and Motor Control Centers

'

       The following switchgear and motor control centers were
       inspected:
            Motor Control Center          3EHS*MCC1A4
            Motor Control Center          3EHS*MCC3A2
            Motor Control Center          3EHS*MCC1A1
            Motor Control Center          3EHS*MCC185
            4160V Switchgear              3 ENS *SWG-A
            4160V Switchgear              3 ENS *SWG-B
 (5) Station Batteries and Racks
       The 125V battery rooms including the installed batteries,
       battery racks and associated equipment were inspected. The
       location, mounting, maintenance and environmental control for
       installation of the batteries were compared with the
       applicable requirements and quality records.
            125V DC Battery               3BYS* BAT-1
            125V DC Battery               3BYS* BAT-2
 (6) 125V DC System Equipment
       The following equipment comprising portions of the 125V DC
       systems were inspected for compliance to design documents for
       such items as location, mounting (welds, concrete anchors and
       bolting) and proper configuration.
            Battery Charger               3BYS*CHGR-1
            Battery Charger               3BYS*CHGR-2
            Battery Charger               3BYS*CHGR-3
            Static Inverter               3VBA*INV-1
            Static Inverter               3VBA*INV-2
            Distribution Panel            38YS*PNL-2
 (7) Control Panels
       A number of Class 1E electrical control panels were inspected
       for compliance to requirements for items such as location,
       mounting and type.    The panels inspected were:
           Main Control Board             3CES*MCB-MB4
             (Reactor Coolant)
           Main Control Board             3CES*MCB-MB2
             (Engineered Safeguards)
           Aux Relay Panel                3RPS*RAK0TXB
           Aux Relay Panel                3CES*RAKAUXA
           Main Control Board             3CES*TB-MB8P
             (Termination Cabinets)
           Aux Shutdown Panel            3RPS*PNLAS
                             II-12
   (8) Motor Operated Valves
         Three motor operated valves were examined in detail.
                           3SIH*MV8923A
                           3SIH*MV8821B
                           3SIL*MV8804A
  The following documents provided the basic acceptance criteria
  for the inspections:
        SWEC Quality Assurance Directive QAD-10.11ML, " Electrical
        Equipment Installation Inspections," Rev. O
        SWEC Quality Standard QS-13.12ML, " Material / Equipment
        Maintenance," Rev. 0
        SWEC Quality Control Instruction FM3-S10-51-010 " Inspections of
        Equipment Subjected to NNECO Pre-Turnover Checkout Program."
        SWEC Quality Control Instruction FM-S13.12-01B, " Preventive
        Maintenance Inspection Schedule."
        SWEC Construction Methods Procedure 1.12-3.79," Material /
        Equipment Maintenance."

b. Inspectior Findings

  (1) Motors
        In general, the installation of Class 1E motors was found to
        be in accordance with applicable design documents. Motors
        examined were of the size, type and configuration specified
        and construction maintenance activities had been performed in
        accordance with approved procedures. However, deficiencies in
        the areas of motor mountings and post-turnover maintenance
        activities were identified.
        Regarding the mounting of several of the motors examined, NRC
        CAT inspectors observed that large diameter mounting bolts
        used to attach motor bases to the associated pump skids did
        not contain the required material marking. This issue is
        discussed in detail in Section VI, Material Traceability and
        Control, of this report.
        During the inspection of electrical equipment, it was not
        evident that adequate maintenance had been performed on some
        electrical equipment. No formal documentation existed to
        verify that required maintenance activities have been performed
        on several pieces of electrical equipment while under NNECO
        control. Examples include the Class 1E Residual Heat Removal
        pump motors for which documented evidence of shaft rotation
        does not exist since the time of construction turnover in March
        of 1983. This issue is discussed in detail in Section III,
       Mechanical Construction, of this report.
                              II-13
                                                                         -
                             - _ _ _ _ . - -   . _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ ____ __ -
       No other deficiencies were identified relative to the
       installation of Class 1E motors.
 (2) Electrical Penetrations
       Penetrations examined were found to have been installed in
       accordance with applicable design documents. Installation
       requirements including performance of required maintenance
       activities had been accomplished in accordance with approved
       construction procedures.
      During the inspection, NRC CAT inspectors identified three
      penetration assemblies whose integral pressure gauges exhibited
       zero pressure readings. A review of inspection records indi-
      cates that pressure requirements had been maintained during
      construction. However, additional discussion disclosed that
      the licensee's position was that positive pressure was not
       required on these assemblies during plant operation. To
      augment this position the licensee presented a copy of a
      telecon with Conax Corporation in which the vendor stated that
      there were no requirements to maintain penetration pressure
      during plant operation, but a positive nitrogen pressure of 15
      psig was recommended to verify penetration leak tightness.
      Subsequent to the NRC CAT observation of penetration pressure
      readings, licensee personnel depressurized all remaining
      penetration assemblies.
 (3) Circuit Breakers
      The examination of the selected circuit breakers indicated that
      they had been purchased, installed and maintained in accordance
      with the applicable design documents. Important installation
      attributes such as proper alignment and main contact penetra-
      tion were verified by physical inspection and review of
      construction test records. Maintenance records were also
      reviewed, and they indicate that lubrication and set point
      verification had been performed.
      NRC CAT inspectors also evaluated licensee initiated actions
      and review of NRC Information Notice 83-18 " Failures of the
      Undervoltage Trip Function of Reactor Trip System Breakers"
      and NRC Generic Letter 83-28 " Required Actions Based on Generic
      Implementations of Salem ATWS Events." NRC CAT inspectors
      noted that Millstone Unit 3 design will utilize Westinghouse
      type DS-416 breakers in the Reactor Trip System. The review of
      supplemental actions to Generic Letter 83-28 indicates that the
      licensee plans to comply with Westinghouse proposed corrective
      actions and will ensure that all DS-416 reactor switchgear
      undervoltage attachments are replaced with a new design and
      tested prior to the current fuel load date.
                            II-14

-

                           ~

k  ; . . . , .

           1
                                           1
                                  (4) Switchgear and Motor-Control ~ Centers
                                        ,In general, the installation of Class IE 4160V switchgear and      t
       *
                                        ; motor control centers was found to be in accordance with
                   -
                                         . applicable requirements.-
                                          Bolting materials used in 'the assembly of some motor control
                                          centers did not contain . identification markings and thus were
                                        .of indeterminate material type. This issue'is discussed in
                                        -detail.in Section VI, Material. Traceability and Control
                                          of this report.
                                  (5) Station Batteries and Racks-
                                          The condition'of the battery rooms was found to be in good

'

                                          order, clean and free of debris. Ventilation systems were
                                          installed and in' operation. Access to these areas was
                                          controlled by keyed entry, and the appropriate danger signs
                                          had been posted to indicate no smoking or open flames.
                                         The 125V batteries were examined in detail,and found to be in
               >
                                          good condition. Maintenance activities were reviewed and, in
   <
                                          general, had been performed in accordance with. requirements.
                                         The inspection of the 125V battery racks disclosed that L        .
                                          indeterminate bolting material had been used in the assembly
                         ,
                                         process. This issue-is discussed in detail in Section VI,
                                         Material Traceability.and Control, of this report.
                                  (6) '125V DC System
                                          Inspection of components comprising the 125V DC system
                                         disclosed no deficiencies relative to the installed
         ,
                                         configuration of the equipment.
                                '(7) Control Panels
                                         The various control panels examined were installed in accord-
                                         ance with applicable design documents. With the exception of
                                         the main control panel wiring separation deficiencies discussed

, -

                                          in Section II.B.2.b(2) of this report, no significant deft-
             ,
                                         ciencies were noted.
                                 (8) Motor Operated Valves

'

                                         Motor operated valves examined were installed and maintained
                                         in accordance with applicable design documents.
                             c.  Conclusions
                                 The installation of Class 1E equipment and associated hardware at

! Millstone Unit 3 was generally found to be in accordance with the l

                                 applicable design documents.

i

 -
                                                               II-15
                 '

. - i L s..

,

      Indeterminate fastening materials have been used in the assembly or
     mounting of several pieces of electrical equipment for which
     seismic bolting requirements apply.
      It was not evident that adequate maintenance activities had been
     performed on some electrical eouipment after turnover to NNECO.
 4.  Instrumentation Installation
 a.  Inspection Scope
     The NRC CAT inspectors selected a sample of instrument components
     from various instrument systems at several plant locations to
     determine whether installations met applicable design requirements
     and installation specifications. Additionally, several instrument
     loops were selected for detailed inspection of signal path routing.
     Fourteen instruments were examined for conformance with requirements
     such as location, mounting details, instrument type and comparison
    of as-installed ranges with design parameters.
    Four instrument racks and nine instrument tubing supports were
     inspected for such attributes as installed configuration, mounting
    details, material, location and identification.
    Eleven completed runs of instrument tubing, comprising about 800
    feet, were examined in detail for such installation requirements as
     location / routing, supports, support location and physical inde-
    pendence of redundant systems.
    The signal paths of six instrument loops were traced from their
    process connections to their final output devices. In most cases
    the components inspected for each loop included sensing lines,
    transducers, signal conditioning and isolating devices, indicating
    and controlling instruments and the various interconnecting cable,
    electrical penetrations, panel wiring and terminalt along the
    signal path. Most instrument components were examined for such
    attributes as type, range, output, identification, qualification,
    location, mounting and physical separation of redundant
    components.     Interconnecting cable, panel wiring and terminations
    were inspected also relative to applicable requirements.
    Refer to Table II-5 for a listing of the instrumentation sample.
    The following documents provided the basic acceptance criteria for
    the inspection:
    *
           SWEC Specification 2472.800-943, " Instrumentation Installation,
           Piping, and Tubing," Rev. 9
    *
           SWEC Specification 2400.000-350, " Electrical Installation,"
           Rev. 7
                                II-16

i

 b.  Inspection Findings
     In general, the installation of instruments, racks, tubing runs and
    supports conformed to appropriate requirements; however, a few
     isolated discrepancies were identified. Two instances of bent
                        were noted: the high and low lines for flow
    ~instrumenttubingFT678(approximately18inchesfromtheroot
    transmitter 3CCP
    valves) and a line for flow transmitter 3FWA*FT51A (between supports
    H009 and H010).    Three instances of loose or missing tube block .
    clamps were noted: the top half on support EK-501035-H002 and the
    top half on support EK-501132-H010 were missing, and the tube block
    on support EK-50134-H010 was loose. As a result of the above
    discrepancies, SWEC QA Inspection Reports 15A00543, 15A00544,
    15A00545 and 15A00564 were issued to document these identified
    conditions.
    The signal paths through the various instrument components and
    interconnections in the six instrument loops inspected were as
    shown on applicable drawings and related installation documents
    except for a few minor discrepancies. For example, SWEC Drawing
    EE-3HB, Rev. 3, shows cable 3SIL2PX802 from Protection Set 2
    (3RPS*RAKSET2) to the Main Control Board (3CES*MCB-M82) to be
    connected to jack 27. The cable was plugged into jack 26. As a
    result of this observation, Inspection Report E5A01801 was issued
    to document this condition. In addition, a number of cable and
    panel wiring separation discrepancies were identified in which the
    installation did not meet the separation criteria specified in the   .
    Millstone Unit 3 FSAR.     This matter of separation of electrical
    circuits is discussed in detail in Section II.B.1 of this report.
    In general, the installation of the instrument loop components,
    associated hardware and interconnections selected for inspection
    was in accordance with applicable design and installation require--
    ments.
 c. Conclusions
    Instrument components inspected were installed, in general, in
    conformance with applicable requirements. The signal paths of the
    instrument loops examined were generally as specified on applicable
    drawings and installation specifications.     The identified
    discrepancies are considered to be minor.
                                II-17

o

                                   TABLE II-1
            DOCUMENTS ISSUED AS A RESULT OF THE NRC CAT INSPECTION
                   ELECTRICAL AND INSTRUMENTATION INSPECTION
 Document Number *       Subject              Document Number      Subject
 IR ESA01335             Cable                IR E5A01325          Cable
 IR ESA01331             Cable                N&D 11,936           MCC's
 N&D 11,932              MCC's                N&D 11,922           Cable
 N&D 11,923              Cable                E&DCR TE-03663       Bolting
 IR ESA01809             Cable                IR ESA01843          Bolting
 IR E5A0348              Cable                N&D 11,904           Bolting
 IR E5A01910             Conduit              E&DCR FE-41807       Separation
 N&D 11,905              Bolting              IR ESA01873          Anchors
 Change Notice 2         Separation           IR E5A01210          Anchors
 (NEAM 128)
 IR ESA01801             Cable                N&D 11542            Anchors
 DCR 742                 Terminations         E&DCR TE-03885       Terminations
 TR 19M3112101           Terminations         E&DCR FE-41870       Terminations
 TR 19M3112742           Terminations         IR E5A01782          Terminations
 IR ISA00545             Instrumentation      E&DCR TE-03766       Te'eminations
 IR ISA00544             Instrumentation      IR E5A01756          Terminations
 IR ISA00564             Instrumentation      IR ESA01796          Terminations
 IR ISA00543             Instrumentation      IR ESA01808          Terminations
 *IR:     Inspection Report
  N&D:    Nonconformance and Disposition Report
  E&DCR:  Engineering and Design Coordination Report
  DCR:    Design Change Request
  TR:     Trouble Report

l l

                                      11-18
             -
   *     e
       3
                                                          ' TABLE II-2
     s
                                                  RACEWAY INSPECTION SAMPLE
                    - Cable Tray:
                                   3TC1270         3TC1280           3TC1250          3TC1020         3TC1310
                                   3TC1030        ~3TC3000           3TC3010          3TC3029        -3TC3030
                                   3TC4490         3TC4160           3TC4170          3TC4180         3TC4200
                                   3TC4210        ~3 TL0010          3TL0020          3TL0030         3TLOO40

g '

                                   3TC007P     .-  3TC006P;          3TC005P.         3TC004P         3TC003P-

l

 x                                 3TC002P        :3TC010P           3TC440P          3TC441P         3TC444P.
                                   3TC443P         3TC444P           3TC445P          3TC446P-        3TC447P-
 '
                                  -3TC448P-        3TC413P           3TC415P          3TC414P         3TC8800
       -
                                   3TC8810         3TC8820           3TK860P          3TK861P         3TK862P
                  '
                                   3TK863P         3TK864P           3TK865P          3TK866P         3TK867P
                                   3TH8800        ~3TH8810'
                     Cable1 Tray Supports:
                                   Support No.       Drawing No.              Support No.      Drawing No.
                                   G203-42            34EN-2                  G217-5            34EN-2
                                   G400-31            34EM-3                  A104-43^          340X-8
                                   A183-65            340Y-8                  A169A-40          340Y-10-
                                   A201B-25           34DZ-9                  C297A-1           34DL-10
                                   C101-188           34DN-10                 R260A-36          34EF-8
                                   R254-53            34EF-8

L

                                                              II-19
L _- _ _ -- - _ _ - - _- - - .                                                                                 .

rn -

                     ~-
 s
                                                                                                                                      ]
   1
                                                                                 TABLE II-2 (Continued)
                                                                                RACEWAY INSPECTION SAMPLE
          Conduit Sample:
                 Conduit No.                                                   Length (Ft)                Conduit No.     Length (Ft)
                 3CK003PD5                                                          110                   3CC003PB1          42
                 3CL0020A                                                            76                   3CX999RF2          22
                 3CC002PA                                                            70                   3CX900BC1          61
                 3CL1060E                                                            20                   3CX1060A5          80
                 3CL103PB                                                            50                   3CC9310K           27
                 3CC128PB                                                            12                   3CC9310C7          28
                 3CC1000C1                                                           80                   3CK926GA           41
                 3CK9260A                                                            26                   3CC441005          58
                 3CK404RB                                                            65                   3CC407PE           27
                 3CC950BB2                                                           61                   3CX950BA4          89
                 3CC4120A                                                            20                   3CC864PB           20
                 3CX926PG2                                                           46                   3CC1080G            2
         - Conduit Support Samplei
                 CB-1305                                                             MA-939
                 MA-1060                                                             MA-1245
                 CS-549                                                              CS-550
                 CS-1711                                                             MA-518                                            .
                 MA-760                                                              ES-943
          Concrete Anchor Sample:
                 Anchor Size                                                   Aux Bldg          ESF Bldg       Cont Bldo     Total
                  3/8" dia.                                                       0                2                0            2
                  1/2" dia.                                                      4                 8               12          24
                  5/8" dia.                                                      4                 0                0            4
                  3/4" dia.                                                       7                9                6          22
                     TOTAL                                                      I5                B                T5          5'2
                                                                                                                                       i
                                                                                            II-20   ,

L .__ __ ___ _ ____ _ _ _ _ _ _ __ _ _ _ ___ _ _ _ __ _ _ _

e .

                                                s
 '   ~
                      '
                -
                                        TABLE II-3-
                           CABLE TERMINATION INSPECTION SAMPLE
        _
                                                                             .
          Original Sample
               Main Control Board.3CES*MCB-MB4, Dwg. EE-3AJH-4, EE-3AJS-2,
              'EE-3AJX-4 and EE-3AKN-4: 19 cables
   4
                                                    '
             '.Te'rmination Cabinet 3CES*TB-MB10,~ Dwg. EE-3DK-6:   70' cables
               Logic. Cabinet "A" 3RPS*RAKLDGA,'Dwg'. EE-3GK-3:   29 cables
               Logic Cabinet "B" 3RPS*RAKLDGB, Dwg. EE-3GT-3:     29 cables
               Aux Shutdown Panel 3RPS*PNLAS,- Dwg. EE-3JA-4:   24 cables
               Aux Shutdown' Panel 3RCS*PNLAS, Dwg. EE-3JB-5 and
               EE-3JD-3: 47 cables
          Expanded Sample
                            ~
               Termination Cabinet 3CES*TB-MB10, Dwg. EE-3DL-5:     73 cables
               Termination Cabinet 3CES*TB-MB1P, Dwg. EE-30P-5 and
               EE-3DQ-5: 152 cables
                                          11-21
                                       TABLE II-4
                            CABLE TERMINATION DISCREPANCIES
 Engineering Discrepancies
 1.   Drawing EE-3DP-5 shows the BLK and WHT conductors of cable 3BDGAPC606 as
      spares. As installed, the BLK wire is on terminal block (TB) 641, pt. 7
      and the WHT wire is on TB-641, pt. 11. This configuration is consistent
      with the original design, but on September 12, 1983, schematic diagram
      ESK-78H-8 was revised to " spare" these wires, causing Dwg. EE-3DP to be
      revised similarly. However, the SWEC site engineering group (SEG) failed
      to issue revised termination tickets to direct construction forces to
      perform the revision.
 2.   Drawing EE-3DP-5 indicates an ORG-BLK wire to be terminated on TB-641,
      pt. 8, but does not show which cable this wire comes from.     The licensee
      stated that this is a drafting error and that this wire is from cable
      3SSRAPC602.
 3.   Drawing EE-3DP-5 shows the BLK and WHT conductors of cable 3BDGCP606 as
      spares. As installed, the BLK wire is on TB-642, pt. 27 and the WHT wire
      is on TB-642, pt. 6.    This configuration is consistent with the original
      Jesign.    However, on September 12, 1983, schematic diagram ESK-7BH-8 was
      revised to " spare" these wires, causing Dwg. EE-3DP to be similarly revised,
      but SWEC/SEG failed to issue revised termination tickets to direct construc-

.

      tion forces to perform the revision.
 4.   Drawing EE-3DQ-5 shows the RED-BLK and WHT-BLK conductors of cable 3BYS1PB605
      as spares. As installed, the RED-BLK wire is on TB-663, pt. 12 and WHT-BLK
      wire is on TB-662, pt. 26. This configuration is consistent with the
      original design. On September 12, 1983 schematic diagram ESK-78K-5 was
      revised to " spare" these wires, cauc' , drawing EE-3DQ to be similarly
      revised.    However, SWEC/SEG failed .o issue revised termination tickets to
      direct construction forces to perform the revision.
 5.   Drawing EE-3DL-5 shows a BLK conductor on TB-634, pt. 25 but does not
      indicate which cable this wire comes from. The licensee stated that this is
      a drafting error and no wire is needed at this point. This discrepancy
      reflects incomplete engineering review of design changes prior to issuing
      revised drawings.
 6.   Drawing EE-3JA-4 shows the BLK, ORG, WHT-BLK, and BLU conductors of cable
      3RCSB0C005 on TB-2T10, pts.1 through 4, respectively. As installed, these
      wires are WHT-BLK, BLU, BLK, and ORG on TB-2T10, pts. 1 through 4, respec-
      tively. The installed configuration is in accordance with drawing Rev. 1.
      However, drawing Rev. 3, dated May 9, 1984 revised this configuration, but
      SWEC/SEG failed to issue revised termination tickets to direct construction
      forces to perform the revision.
                                         11-22

r

                                  TABLE II-4 (Continued)
                              CABLE TERMINATION DISCREPANCIES
 7.-   Drawing EE-3GK-3 shows the shiel'd of cable 3ISCA0X800 on TB-517, pt. 1.
       As installed, this shield is on TB-517, pt. 4. A review of the termination
       ticket issued by SWEC/SEG to construction and QC shows that TB-517, pt. 4
       was' erroneously indicated on the ticket.
 8.    Drawing EE-3AJX-4 shows the WHT-BLK conductor from cable 3EGPA0X403 on
       the TB-DBF, pt. 9 and the RED-BLK wire on TB-DBF, pt.10. As installed,
       pt. 9 has a BLK wire and pt.10 has a WHT wire from this same cable. This
       cable is a two-conductor cable containing only BLK and WHT wires. The
       licensee stated that this is a drafting error and that the as-installed
       wiring is correct. Drawing errors of this nature reflect inattention to
       detail during engineering review.
 Post-Turnover Discrepancies
 9.    Drawing EE-3DP-5 requires the WHT-BLK conductor of cable 3LMSBPC002 to be
       on terminal TB-640, pt. 9. Although the QC inspection record shows this
       to be acceptable, the WHT-BLK conductor is not presently terminated. The
       licensee stated that phase one testing of this circuit is not yet complete,
       and that upon completion of such testing, a design change request would
       be issued, if necessary, to document this condition. This response is
       not consistent with the requirements of Section 5 of the Northeast Nuclear
       Energy Company, " Millstone 3 Startup Manual," Rev. 3 which requires that
       wiring changes / deficiencies be documented upon discovery.
 10.   Drawing EE-3DP-5 shows the RED conductor of cable 3CCPBPC350 at TB-648,
       pt. 18 and the GRN-BLK wire as a spare. As presently installed, the RED
       wire is spared and the GRN-BLK is at TB-648, pt. 18. Original QC inspection
       records show these wires to be acceptable par drawing requirements and the
       RED wire is actually cut shorter than other spares in the vicinity and is
       the appropriate length to have once been terminated at the required point,
       indicating that these two wires have been " swapped" subsequent to QC inspec-
       tion.    The licensee stated that, although phase one testing of this circuit
       is complete, no documentation has yet been issued to document this revision
       as required in Section 5 of the Startup Manual.
 11.   Drawing EE-3DP-5 shows the ORG-BLK conductor of cable 3CCPBC615 as a spare,
       however it is terminated at TB-654, pt. 20. Original QC inspection records
       show this wire to be acceptable per drawing requirements and the wires in
       this circuit are tagged to indicate that phase one testing is in progress.
       The licensee stated that, as phase one testing is not yet complete, a design
       change request will be issued to document this condition upon test comple-

, . tion, if necessary. This is not in accordance with Section 5 of the Startup l Manual. l l l

                                           II-23

_

                                  TABLE II-4 (Continued)
                             CABLE TERMINATION DISCREPANCIES
 12.    Drawing EE-20Q-5 shows the BLK-WHT conductor of cable 3BYS1PC601 on TB-666,
      _pt. 15. This wire is presently on TB-666, pt. 14. The original QC inspec-
        tion records show this to be acceptable per drawing requirements. The
        licensee stated that phase one testing of this circuit is not yet complete,
       and that upon completion of such testing, a design change request would be
        issued, if necessary, to document this condition. This response is not
       consistent with the requirements of Section 5 of the Startup Manual, which
       requires that wiring changes / deficiencies be documented upon discovery.
 13.   Drawing EE-3DK-6 shows the GRN-BLK conductor of cable 35WPAOC350 on TB-609,
       pt. 22 and the WHT-BLK wire on TB-609, pt. 24.     The as-installed configu-
       ration is exactly opposite of that required. The original QC inspection
       records indicate that these wires were correctly installed as of March 22,
       1984, and the present appearance of the wires indicates that they have been
       " swapped" subsequent to QC inspection.     No documentation was available to
       justify this change.    This is not in accordance with Section 5 of the
       Startup Manual.
 14.   Drawing EE-3GK-3 shows the BLK conductor from cable 3RPSA0X812 on TB-506,
       pt. 4 and the WHT on TB-506, pt. 5. The as-installed configuration is BLK
       on pt. 5 and WHT on pt. 4. The licensee indicated that, although phase one
       testing of this circuit is complete and the circuit operates correctly, no
       documentation had been issued to substantiate the wiring change.      This is
       not in accordance with Section 5 of the Manual.
 15.   Drawing EE-3GT-3 shows the BLK conductor of cable 3RPSBPX812 on TB-506,
       pt. 4 and the WHT conductor on TB-506, pt. 5.     As installed,_the BLK wire
       is on pt. 5 and the WHT wire is on pt. 4. The licensee indicated that
       although phase one testing of this circuit has been completed ard the
       circuit operates correctly, no documentation had been initiated to substan-
       tiate the wiring change. This is not in accordance with Section 5 of the
       Startup Manual.
 Minor Discrepancies
 16.   The WHT conductor of cable 3CHSNOC152 (Dwg. EE-3JB-5, TB-3T14, pt. 7) was
       found with a cut in its jacket.
 17.   Drawing EE-3AKN-4 shows the shield from cable 3BYS2PX401 on TB-DBW, pt.
       22 and the shield from cable 3BYS2PX451 on TB-DBW, pt. 21. As installed,
       these shields are interchanged.     Because these two points are jumpered
       together on the other side of the terminal strip, there is no functional
       difference in the circuit between the as-installed and specified conditions.
       However, design change request 742 has been issued to document this find-
       ing.
                                           II-24
                                TABLE II-4 (Continued)
                            CABLE TERMINATION DISCREPANCIES
 18. The BLK and WHT conductors of cables 3WTCBPC621 and 3WTCAOC613 were found
     to be determinated in panels 3CES*TB-MB1P and 3CES*TB-MB10. Bypass / jumper
     tag log sheets 221 and 223, located in the shift supervisor's office, show
     that only the BLK wires are documented as being temporarily determinated.
     As a result of this finding, log sheets 221 and 223 have been corrected to
     indicate that both BLK and WHT wires are determinated. A review of other log
     sheets for similarly determinated cables shows this to be an isolated case.
     In addition, it should be noted that these log sheets were initiated in
     accordance with Procedure ACP-QA-2.06B, " Station Bypass / Jumper Control",
     Rev. 4 which has already been revised (Rev. 5, February 1, 1985) to include
     additional procedural controls which should preclude future errors of this
     nature.
                                         11-25

L

                                        TABLE II-5
                             INSTRUMENTATION INSPECTION SAMPLE
 Instruments:
                        3 MSS *PT515               3LMS*PT936
                        3CCP*FT67B                 3LMS*PT937
                        3QSS*LT930                 3FWA*FT51D
                        3QSS*LS56A                 3FWS*LT519
                        3QSS*LS54A                 3FWS*LT529
                        3LMS*PT93A                 3RCS*FT415
                        3LMS*PT935                 3RCS*FT416
 Instrument Racks:
                        3CES-RK12-04               3CES-RK12-06
                        3CES-RK12-05               3CES-RK12-07
 Instrument Lines:
                        3 MSS *PT515(AW) 30'       3LMS*PT936(BW)   25'
                        3CCP*FT678(BP) 64'         3LMS*PT935(CB)    7'
                        3QSS*LT930(XR) )           3FWA*FT510(00)   81'
                        3QSS*LS56A(X0) )17'        3FWS*LT519(AW) 234'
   '
                        3QSS*LS54A(X0) )           3FWS*LT529(BR) 219'
                        3LMS*PT937(AR) 12'         3RCS*FT416(AB)   70'
                        3LMS*PT934(DY) 21'         3RCS*FT415(AW)   70'
 Tubing Supports:
                        EK-501035-H003             EK-501139-H026
                        EK-501035-H001             EK-501139-H027
                        EK-501034-H005             EK-501139-H016
                        EK-501139-H021             EK-501139-H017
                        EK-501139-H024
 Instrument Loop Verification:
 Steam Pressure
       Loop Function:    Senses steam generator 1A outlet pressure, provides
       an input (trip) signal to the reactor protection system (RPS); indicates
       steam line pressure on the main control board (MCB) and on the auxiliary
       shutdown panel.
       Components: The sample included the sensing line from the steam generator
       outlet steam line to pressure transmitter 3 MSS *PT515, parts of the RPS,
       pressure indicators 3 MSS *PI515A and 3 MSS *PI5158, and interconnecting
       cable, panel wiring and terminals.
                                           II-26

L

                    ~

% _.a

                  .
          ,
  ,~       , .
                                                        : TABLE II-5-(Continued)
                                                INSTRUMENTATION INSPECTION SAMPLE
              ! Pressurizer Pressure-
                          Loop Function:    Senses ~ pressurizer' pressure and provides an input (trip)
                          signal.to the RPS, the engineered safety-features actuation system and
                        ._ indicates' pressurizer.. pressure'.on the MCB.

'

                       < Components: - The sample included pressure transmitter 3RCS*PT456, electri-
                          cal penetration.3RCP*G1,~ parts-of the signal conditioning and logic
                          circuitry-(Channel II) of.-the RPS, pressure _ indicator 3RCS-PI456A and
                          interconnecting cable, panel wiring and terminals.
               Reactor Coolant: Loop Flow
,
                          Loop Function: Senses reactor. coolant loop 1 flow and provides an input
                       '(trip) signal to the_RPS and indicates loop flow on the MCB.
                         Components: The sample included the' sensing lines from the loop piping
                       . elbow taps,. flow transmitter 3RCS*FT415, electrical penetration 3RCP*G1,

'

                                            .
 s                     . parts of the signal conditioning and logic circuitry (Channel II), flow-
                       ; indicator 3RCS-FI415 and interconnecting cable, panel wiring and terminals.
              ~ Reactor Coolant Loop Flow.
                         Loop Function: . Redundant-to above loop.
                         Components: . Flow transmitter 3RCS*FT416, electrical penetration 3RCP*C6,
                         flow indicator 3RCS*FI416 and associated components similar to the above
                        ' loop.
 1             RHR Miniflow Recirculation
                      ~ Loop Function:
                                                    ~
                                           Senses residual heat removal pump 3RHS*P1A flow, provides
                 q a signal to operate' valve 3CHS*FCV610 upon high or low flow and indicates -
                    >
                       ; valve position'on the MCB -
                         Components: The sample included flow indicator switch 3RHS*FIS610, valve
                         posi_ tion-indicator 3RHS*FCV610'and interconnecting cable, p'anel wiring
    .
                      :and terminals.
               Safety Injection Accumulator Vent Valve
                      . Loop Function:     Provides. signal to position valve in vent line from the
                        accumulator tanks 3SIL*TK1C&D and provides valve position indication on
                                                      .
      _
                         the..MCB!and the auxiliary shutdown pane 1.
                      . Components: The sample included valve operator 3SIL*HCV943B, indicating
                      -and control instruments 3SIL*HC9438 and ZI943B on the MCB, indicating and
                                                                                    -
                        control instruments 3SIL*HC 9430 and ZI943D on the auxiliary shutdown panel,
        -
                        electrical penetration 3RCP*E3 and interconnecting cable, panel wiring and
                      : terminals.
                                                                  II-27

e

I

   III. MECHANICAL CONSTRUCTION
        A. Objective
           The objective of.the appraisal'cf mechanical construction was to
           determine if installed and Quality Control (QC) acct.pted mechanical
            items conformed to engineering design, regulatory requirements and
            licensee commitments.
        B. Discussion
           The specific areas of mechanical construction evaluated were piping,
           pipe supports / restraints, concrete expansion anchors, mechanical
           equipment, and heating, ventilating and air conditioning (HVAC)
           systems. To accomplish the above objective, a field inspection of a
           sample of QC accepted hardware was performed in each area. In
           addition, certain programs, procedures and documentation were reviewed
           as required to support or clarify hardware inspection findings.
           1.    Piping
           a.    Inspection Scope
                 (1) Piping depicted on the 26 Stone & Webster Engineering Corpora-
                      tion (SWEC) drawings listed in Tables III-la & b was selected
                      for the inspection sample. The piping encompassed portions of
                      the Chemical & Volume Control, Auxiliary Feedwater, Residual
                      Heat Removal, Quench Spray, Charging Pump Cooling, and Safety
                       Injection Systems. Piping configuration (i.e., layout geometry,  ;
                      orientation and dimensions), component identification
                      and location, valve operator orientation, and pipe support
                      location and type were compared to the results on inspection
                      drawings marked-up by SWEC QC during their inspections.
                      Additional features such as maintenance of inservice inspection

./'

                      clearance criteria and site construction practice affecting
                      installed mechanical components were observed where appro-
                      priate. Piping component material specifications were compared
                      to controlled material take-off lists on a random basis. The
                      as-built and stress reconciliation programs were also reviewed.
                 (2) Hydrostatic test records for 20 piping isometrics were reviewed
                      for completeness, accuracy and content. These isometrics
                      encompassed portions of the Chemical and Volume Control, Safety
                      Injection, Residual Heat Removal, Component Cooling, Quench
                      Spray, Auxiliary Feedwater, and Containment Recirculation
                      Cooling Systems.    A listing of the associated piping isometrics
                      are prov.ided in Table III-2a.
                 (3) Seven piping samples represanting approximately 75 feet of
                      pipe were selected to determine whether ASME requirements for
                      pipe wall thickness were met. The measured pipe wall thick-
                      nesses were compared against the minimum wall thickness
                      requirement specified by ASME (12.5 percent below nominal
                      thickness). See Table III-2b for the inspection sample and
                      observations.
                                            III-l

<

              -
                  ~
        *                                                                      '
s
     y w
                                        '                    ~
             .
                                            The following documents ~provided the basic acceptance criteria and

m '

                                           , background-information for the inspections:

f1

      *
           -                               :*'   LSWEC' Specification M968, " Field Fabrication and Erection of
                -               ,                   Power Piping," Rev. 7,: Add; 5.
                              x
   :                                        *-
                                                    SWEC Procedure NETM 31, " Procedure for Seismic Category I
                                  '
                            ,
 ~                                    '
                                                  ' Piping Location Isometric.and Tubing Isometric Review and
                      ,                     +       Stress Reconciliation," Rev.~0, through Change Notice.No. 3-
                                            *
                                                  'SWEC Procedure FCP-337, " Preparing Stress Reconciliation
    .
                    -
                                                    Piping Location Isometrics (PLI's)," Rev.- 3
           '                                *
                                                  'SWEC Procedure NEAM 122, "As-Built Program,"'Rev. 0 through
                                                                                                        .

E

                                    -
                                                 . Change Notice No. 2
                                                 .
                                           '*~
                                                 .SWEC Quality Control Instruction'(QCI) FM3-S14.2-07C,
                                                   "ASME III_N-5 Inspections"
                                            "'
                                                 'SWEC Procedure NEAM 134, " Processing of ASME III Certifica-
 _ ,
                                                   tion," Rev. 0
                                                                                                                        ,
                                            *
                                                 -SWEC QA Attribute List No. M3-SP-968-15-4232 for PLI Inspection
         "
                                          :*
                                                 _SWEC-QA: Attribute List No. M3-SP-968-18-5052 for ASME III
                                                   Fabrication / Installation Inspection
                                            *-     SWEC' Procedure MTP-3, " Generic Pressure Test Guidelines for
                          ,
                                                ' Fluid: Systems," Rev. 2
                                            *-
                                                   SWEC Procedure No. 5.7, " Pressure Testing," ~ Rev. O through~
                                                   Change Notice No. 6
                                          -*       Applicable Piping Isometrics
                                  ' b. -Inspection Findings
                                            The selected sample of piping ranged in size from three-fourths to-
                                            20 inches, and classifications included all ASME pipe classes as
                                          'well as class 4-(ANSI B31.1) piping. .This sample represented
                                            approximately 400 feet of piping-two inches or less in diameter and
                                            approximately 800 feet of piping greater than two inches in
                                            diameter, all of which had been previously inspected and accepted by
                                            SWEC Field Quality Control (FQC). Observations associated with
                                                                                                                     ~~
                                           . specific-piping isometric drawings are listed in Table III-1. A
                                            summary of the findings are provided below.
.w                                          (1) During the installation of process piping systems, various
              ,
                                                -inspections by FQC were performed.      The Piping Location      _.
                                                   Isometric (PLI) inspection which verified attributes affecting.
                                                   the as-built effort such as dimensions, was one type of
                                                   inspection. A " pre N-5" inspection followed the PLI inspection,
                                                           ~
                                                   and was conducted.in accordance with QCI S14.2 which directed
                                                   inspection of certain attributes-immediately before the ASME
                                                   N-5 Code Data Report sign-off.
                                                                         III-2

u

p ,  ;

                                                                                               4
    '            '
                                                  lPLIinspections,whichwereperformedinaccordancewith
                                ,                 ; Procedure FCP-337,~ required dimensions to be verified to the
                                                    Piping Specification M968 tolerance _of 0.5-inch. Sixteen
                                                    dimensional errors ranging ~from 1.0 to 13.0 inches were detec-
                          -
 1                                    _
                                                    ted by-.the NRC. CAT'on the 26 drawings inspected. For pre-N-5
                                                    inspections,-QCI S14.2. required reinspection:of all " moveable
                                                  zsupport" location dimensions immediately prior to N-5 sign-off.
                                                   A moveable support-is any support which does not have inte-
 - -                    '
                                      <
                                                    grally welded attachments to the process pipe. Of the 16
                                                    errors previously'noted, four e'rrors which ranged in size from
                                                    1.~0 to 3.0_ inches were detected by the~NRC CAT on the 14
                                                    drawings which had already undergone the later pre N-5 inspec-
                        "
                                                    tion. The NRC: CAT is concerned that the reduced frequency and-
                                              ' . magnitudes of errors (4) found in the already pre N-5 inspected
                                                    sample is not truly indicative of.the effectiveness of the pre
       .
                                                   N-5 inspection since most of the errors (16) were not asso-

Q ciated with moveable supports, and thus would likely not be _ detected:during the pre N-5 inspection.

                                                   During the NRC CAT inspection, SWEC studied the matter of
                                        '
                                                   dimensional discrepancies, evaluated most of the discrepancies,
                                                   and found no resultant unacceptable stress conditions. As_a
                                                   result of the NRC CAT findings, FQC monitored the ongoing pre-
                                                   N-5 inspections for dimensions which were discrepant with those
                                                   found on the PLI drawings ~._ This monitoring showed a substan-
                                                   tially lower error' rate than that found by the NRC CAT; Based
           *
                                                   primarily on the lower incidences of PLI dimensional! error
                              '
                                                  ;found in that sample, FQC concluded that existing QC
                                                   procedures were adequate to. assure the accuracy of piping
                    .                            . dimensions. .FQC also issued a memorandum to piping. inspectors
                                                   which directed random remeasurement of PLI~ verified non-
                                                   moveable support and overall (i.e., straight run total length)
                                                   dimensions.     No additional action was proposed by SWEC
                                                   regarding'this subject.
                                  *
                                                   The NCR CAT is concerned that the FQC sample of PLI dimensional
                                                  ' verification was limited to that piping which was ' inspected ~ for
                                                   N-5 sign-off during a one week period and was.therefore limited
                                                   in both time and scope. The resultant error rate was.not
 >-                .                               consistent with that found during the same period by the NRC
 > '
 ' -
                      .
                                                   CAT. 'We are also concerned that the direction to remeasure PLI
                                                   verified dimensions on a random basis during pre N-5 inspec-
                                                  ~t ions will not provide FQC with a quantifiable data base with
                                                   which to conclude the adequacy of dimensional measurement
                                                   quality control. Although the magnitude of errors detected by
                                                  'the NRC CAT is not extreme, the rate of occurrence warrants-
                                                   additional attention'and-corrective action.
                                          - (2) The PLI for drawing QSS-3 incorrectly identified a support'
                                                   function.- Support PSR-063 was identified as a vertical and
                                                   axial pipe restraint when in fact, the support also restrained
                                                   the pipe laterally. This error appears to be an isolated
                                                   instance, and not-indicative of the overall QC effort.
      e
                            s
             , - -
                                                      -
                                                                          III-3

6: '

                                 --
        2
                   7              -
                                                       ,
          ,
                 m
                                                 Three drafting errors' associated with isometric CHS-31 were
       ^'
               .                                . detected by the NRC CAT. .At least.two of-these errors, one
                           "
                                                 missing 1 dimension and one support for which neither the mark
    '
                                                . number nor function were identified, would have been detected
                                               -during completion of the as-built reconciliation effort. The
                                                                             -
                                                ' third er_ror.was a misorientation of a small pipe angle. These
                                                 drafting errors appear to represent isolated instances.
                        ~
         .^'
                                                 A total /of three violations to specified clearance criteria
                                       .         were< identified in our piping sample. 'In general, pipe
                                                . clearance < violations between other mechanical and structural
            '
                                                . components were found to.be accurately. recorded for disposition
                         -
                                               'by engineering-during the as-built stress reconciliation
                                               ^ analysis effort.
          '
                      -
                                          (3)     In conjunction with the NRC CAT review of. design change control-
        <
                                                  (Section VII), it was observed that the implementation of E&DCR
                                                 FP-22607 regarding the addition of a valve to process
                                               -pipe, was'not. proper in that a steel plug was used on the
                                                                                                             _
                               -
                                               - Category II 'end of a valve _ nipple instead of a nylon plug -
      '
                                                ~as specified by the E&DCR.     The NRC CAT does not consider this.
      ,
                                 '
                                                 particular discrepancy to be significant in nature, but is
                                            .
                                                 nonetheless a condition'of noncompliance with respect to the
                             ~
                                                 E&DCR. 'Although Category II piping is not subjected to the
                                                 same scrutiny of inspection as Category I piping, the licensee
                                    ~~
                 ^
                                                 should be aware of the potential for misinstallations in
                                                 non-FQC inspected portions of Category II systems.

-

                                          (4) In the course of the NRC CAT inspection of welding (Section-
                                                 IV), it was determined that a weld preparation detail which
                                                               ~
                                                 affected piping design'was not adequately addressed by'SWEC
                                                 Engineering in that weld joint-stress considerations had not'-
                                                                                                               ~
                                               ~ been evaluated for the revised configuration. This weld detail
         ,-                                      required counterboring of the process pipe at the feedwater to
                                                 steam generator nozzle connections.      Resultant stresses were
                                                 not evaluated for the reduced cross-sectional area as a result
                                                 of the counterboring. . In response to NRC questions, SWEC later
                                                 determined that pipe stresses for these nozzle details met Code
                                                 stress limits. SWEC also determined that mechanisms to alert
                                                 SWEC Engineering of_such unusual weld preparations were in
                                                 place and that they had adequately addressed-such nozzle
                 ~
                                                 details'affecting other equipment' supplied by the same NSSS
                                                 vendor. Since this discrepancy appears to be aniisolated case,
                                                 a review of similar circumstances-for nozzles ~ supplied by
                                                 vendors-other than the'NSSS vendor was not undertaken by SWEC
 3                                               at the time of our inspection and is not contemplated.
                                          Regarding-hydrostatic / pneumatic test packages, approximately 34
                                          inspection-records were reviewed for the 20 piping isometrics

,~

                                          selected. Pressure testing of embedded portions of piping were
                                         -performed in'accordance with Test Procedure MTP-3 by field engi-
                    ~
                                          neers, and witnessed by FQC. Pressure testing of exposed and
                                          completed piping systems were performed in accordance with pressure
                                          Test Procedure 5.7, and were' generally performed under the direction

s of the Advisory Operations organization, with FQC performing the

                                                                        III-4
              _
  -
     witnessing and documentary functions.    The NRC CAT inspector did not
      identify any deficiencies such as missing or improper records,
      overpressure or underpressure, or conflicting information in the
      record packages kept by SWEC Construction FQC.   Record packages for
     pressure tests that were either stored in the vault or kept by
      the Advisory Operations organization were not reviewed.
     The NRC CAT did note, however, that on many of the associated
      inspection reports which listed the applicable weld identifica-
     tion numbers within the particular test boundary, various welds
     were deleted from the test boundary after the date of the test.
     These welds were then included within the test boundaries of other
     pressure test isometrics which were to have been performed at a
      later time.
     Conversations with FQC personnel indicate that the FQC inspector (s)
     who witnesses the pressure tests does not perform a point by point
     weld identification comparison with the isometric drawing (s) when
     walking down a pipe run. Rather, the welds are implicitly identi-
     fied; it is assumed by the FQC inspector (s) that all welds which are
     inspected between two reference points correspond to the weld
     numbers listed in the inspection report by virtue of their physical
     existence.
     The NRC CAT is concerned that these types of inspection and docu-
     mentation approaches are potential sources for errors such as
     omitting an inspection of a weld, giving inadvertent inspection
     credit for welds, and the failure to detect unauthorized or undocu-
     mentedweldjoints.
     With regard to the seven piping samples selected for minimum wall
     thickness verification, none of the samples were found to be below
     the specified' minimum values. Only one sample was within three mils
     of the minimum will thickness limit. The various samples ranged in
     diameter from one inch to 12 inches, and were specified to meet the
     ASME Boiler and Pressure Vessel Code, Section III, Class 1, 2, and 3
     requirements (as appropriate). Pipe wall thickness was measured
     using ultrasonic methods, with personnel and equipment provided by
     the licensee. Circumferential measurements were taken at the ends
     and the center of the samples; other measurements along the length
     of the pipe were also obtained for those samples in which a poten-
     tial for violating minimum wall thickness requirements appeared
     likely.
  c. Conclusions
     No significant hardware discrepancies were observed in installed
     piping systems. Site engineering and inspection personnel were
     knowledgeable of procedures, requirements and responsibilities. The
     NRC CAT observed evidence of effort to protect installed hardware
     during ongoing construction activities and observed no significant
     problems regarding construction practice. However, we are concerned
     about the number of erroneous measured dimensions identified. We
     are.also concerned that the results of the one time sampling of
     dimensioning by SWEC as a result of the NRC CAT findings, which
                                III-5

!-

                                            --
                                                      - - - -         -__     _              -
                                                                                                            _
 .
                                       _
                     4
                                         ~
                                contradicted the resultsLoffour sampling,' may.not be sufficient'to-
                                conclude the adequacy' of as-built measurements ~. As such, additional
                             ' attention with respect to implementation and/or procedures in this
                                area. appears warranted.
                       .2.      Pipe"Sup' ports / Restraints
                        a. : Inspection Scope
             '

t ,

   '
                               Twenty eight ASME Class 1, 2 or 3 and.five class 4 pipe supports /
           -
                              . restraints which represented a variety of types, sizes, systems and
                 <
                                locations were selected for. detailed inspection. All but four
     -
                               supports-had been QC inspected and. accepted. These supports /
                               restraints were: inspected for-proper configuration, clearances,
                               member size, location,_ weld size, fasteners.:and damage.       See Table
                                III-3;for a listing of the-inspection sample.- In addition, approxi-
                            imately'75 other supports / restraints were observed at random in the
                             -field for obvious deficiencies such as loose or missing fasteners,
                             : improper clearances or angularity, improper locking devices,-
                               disassembled items,-damage and improper concrete expansion anchor-
                               spacing.
                               The FQC-inspection reports for four supports were examined and com-
                               pared with drawings and' current document revision cards to verify-
                               that the required attributes were inspected and that inspections
                               were performed to the latest design documents. This review was con-
                               ducted'for.QSS-1-PSR-146,-QSS-1-PSA-140,-QSS-1-PSR-126 and'
                               CCP-2-PSA-078.
       .
                               Acceptance criteria for these inspections were contained in the
                               following documents:
                               *
                                      SWEC Specification M968, " Field Fabrication and Erection of
                                      Power Piping," Rev 7, Addendum 5
                               *
                                      SWEC Quality Control Instruction QCI FM 3-D10.43-01B, "Inspec-
                                      tion'of Pipe Supports"
       ,
                               *-
                                      SWEC Quality. Standard, QS-10.43ML, " Hanger / Support and Anchor.
                                      Bolt Installation / Inspection," Rev. 0
                               *~
                                      SWEC Quality' Assurance Directive (QAD) 10.43, " Hanger and
                                     -Anchor Bolt Installation Inspection," Rev.- A
                                                                                                         ..
                              *
                                      SWEC Specification M924, " Drilled-In Expansion Type Concrete
                                      Anchors"-
                             .*
                                      Applicable design drawings and change documents.
~
                       b.      Inspection Findings
                              At the time of this inspection approximately 98 percent of the
                              approximately.3800 large bore ASME supports / restraints had been
                               installed and 95 percent had been QC accepted. Approximately 96
               c   .                                          .
                                                                III-6

.-

percent of the 3600 small bore ASME supports / restraints had been installed, with 86 percent QC accepted. The inspection and acceptance criteria for aspects of pipe support / restraint installation (e.g, welding, concrete expansion anchors, Richmond inserts, baseplates, general tolerances, locking devices, special inspections for snubber struts and spring hangers) were com- piled in a controlled digest called the Inspector's Handbook. This handbook provided the inspector easy access to the many pieces of information needed to perform proper support / restraint inspections, in one concise document. For the four supports / restraints which received documentation reviews, examination of the inspection reports indicated that they had been inspected for all attributes and were inspected to the latest design drawings. No deficiencies were identified. However, during our inspection of hardware, a number of discrepan- cies were identified including improper attachment locations, inadequate integral lug contact, less than full flange width beam stiffeners, loose fasteners / locknuts, missing or improperly instal- led bearing spacers, and drafting errors. See Table III-4 for a listing of inspection observations. Although the majority of these discrepancies noted were generally minor in nature, and would not likely affect structural integrity,'several rather significant discrepancies were identified. They are discussed as follows: (1) Five instances were noted where support attachment locations

     were not as shown on design drawings.    Discrepancies were
     noted on attachment points to embedded plates, structural
     beams and tube steel support members. Three cases involved
     lateral positioning, one case involved axial positioning,
     and one case involved attachment location on an embedded
     plate. The causes of these discrepancies appear to include
     inadequate attention to detail by QC inspectors, lack of
     specific dimensional location requirements on drawings, and
     confusion between Engineering and FQC as to the allowable
     tolerance for attachment locations. FQC personnel indicated
     they had been applying a plus or minus one inch piping location
     tolerance to support attachment locations. The discrepancies
     observed by the NRC CAT exceeded the one inch tolerance.
     In addition, FQC stated that they had utilized the support
     location tolerances shown on the support location sketch,
     which was depicted on the BZ (support design) drawing. This
     support location tolerance, which was as much as two feet in
     some cases, was based on pipe stress analysis considerations -
     not on support design considerations. SWEC Engineering
     indicated that the standard dimensional measurement tolerance
     of plus or minus one eighth inch was assumed to have been
     used by FQC, unless otherwise stated.
                           III-7
                                 -                    .                 .   . . ~ -   -                  .     _.       _ . .m
                               I

4

                                                 'The BZ drawing support location sketch for SWP-4-PSST-117
                                                   showed allowable relocation (from a pipe stress standpoint)
                                                  of 24 inches. The attachment point for this support had
                                                  been. moved the full 24 inches from the design location on
                                                   the axis of a tube steel beam, and had subsequently been
                                                  accepted by FQC. When the NRC CAT questioned the application
                                                  of this tolerance for this support,.FQC and Engineering
                                                  responded that the condition was acceptable. However, when
                                                   the NRC CAT inspector reviewed the support design calculation,
                                                   it was determined that a three inch tolerance to the specified
                                                 ' location had been used.
                                                  Preliminary calculations indicated that based upon original
                                                  design location and configuration an overstressed condition
                                                  existed. Subsequent analysis by SWEC Engineering confirmed
                                                  that stress allowables had been exceeded. However, a
                                                  reevaluation utilizing as-built weld sizes and loading
                                                  configurations showed the support to be not overstressed,
                                                  and in fact, to be within acceptable limits.       Prior to the
                                                  conclusion of the NRC CAT inspection, a " Report of a
                                                  Problem" had been generated by SWEC Engineering to address
                                                  the one-eighth vs. one inch tolerance question.
                                                  In addition,-the NRC CAT is concerned that wide location
                                                  changes have not been generically accounted for in support /
                                                  restraint design calculations. The NRC CAT inspectors

'

                                                  consider.that the clarity of attachment location tolerances
                                                  and the adequacy of FQC inspections need to be comprehen-
                                                  sively evaluated. Clear acceptance criteria for these
                                                  situations need to be established with reanalysis and
                                                  reinspection performed as required.
                                          - (2) In the case of axial restraints on pipe risers utilizing welded
                                                  lugs or. trunnions, FQC inspection criteria required that only
                                                  one lug or trunnion be in contact with the restraint member.
                                                  However, the calculation for a spring support on a riser,
    . '
                                                  3-MSS-1-PSSH-128, reflected the assumption that the load was
                                                  shared by two lugs. At the request of the NRC CAT, SWEC                      ,
                                                  Engineering researched and identified a total of 45 cases of
                                                  conflicting load sharing assumptions on spring supports on
                                                  risers. The cause of this problem apparently came from a
                                                  general relaxation of-the inspection criteria from two lugs-to
                                                  one lug in contact, when in fact the design guide for spring
                                                  hangers indicated load sharing by two lugs. Where more than
                                                  one lug contact was assumed or required by calculations, the
                                                 designer did not specify the required additional contact on the
                                                 design drawing for QC to verify. An earlier special support
                                                 design review initiated and conducted by SWEC Engineering which
                                                  included an evaluation of integral welded attachment assump-
                                                  tions, failed to identify this discrepancy with regard to
                                                  spring supports.
                                                 Subsequent to the NRC CAT identification of this item, an
                                                 evaluation of loading dynamics by SWEC designers indicated that
4
                                                  single lug contact would be adequate for spring supports. When
i

j , III-8

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

F

       requested to determine the applicability of this problem to
       rigid axial restraints, it was determined that all but the RHS
       system had been or would be included in the aforementioned
       special design review. A review of the RHS system requested by
       the NRC CAT revealed that two of the nine supports / restraints
      of the type in question had been designed assuming load sharing
      by more than one lug. E&DCRs were issued to have F
       the required contact and/or add shims as necessary.QC verify
 (3) The NRC CAT inspectors identified an occurrence where stiffener
      plates for a wide flange beam did not span.the width of the
      beam. Support CCP-1-PSR-154 had beam stiffener plates which
      were 5/8 inch short in span. After this was identified, SWEC
      FQC performed a random field inspection of stiffener instal-
      lations. Of 290 plates installed on 119 supports / restraints,
      six plates on three supports were also found to be undersized
      (five were 1/2 inch short and one was 5/8 inch short). FQC
      personnel were apparently applying a " cut to suit" note on
      design drawings to allow deviations in excess of the plus or
      minus 1/8 inch allowed by design. FQC personnel were subse-
      quently reinstructed on the requirements for beam stiffener
      plate installation.
 (4) With regard to the number of NRC CAT observations regarding
      loose fasteners, locking devices and other hardware on accepted
      installations, these deficiencies indicate a need to perform a
      final inspection for these features after construction activi-
      ties are essentially completed. This concern applies to Class
      4 supports (non-safety system supports erected in seismic
      buildings in proximity to ASME piping / components) as well as
      ASME supports.    Discussions with SWEC and NUSCO personnel
      indicated several walkdowns were to be performed prior to plant
      operation which could identify and correct many of these
      deficiencies. NUSCO further committed to include an inspection
      for loose hardware in the ASME Section XI preservice inspection
      program. The NRC CAT considers this an excellent approach, but
      considers that Class 4 supports / restraints in proximity to
      safety-related systems should also receive an equivalent
      inspection.
      The NRC CAT inspectors also examined the licensee's program for
      assuring conformance to NRC Regulatory Guide 1.29, " Seismic
      Design Classification," for Class 4 (Non ASME) piping and
      supports in proximity to safety-related items. The attachment
      welds to Seismic Category I structures and/or the expansion
      anchor spacing on surface mounted plates are inspected by SWEC
      FQC on all Class 4 supports / restraints. Until terminated in
      August 1984, inspections essentially identical to those used
      for ASME supports were performed on 20 percent of Class 4
      supports / restraints. A " hazards analysis" program consisting
      of safety-related area walkdowns by a single design engineer is
      currently being used to identify and evaluate potential
      hazards. The criteria used for the evaluation is based on a
      study of seismic interaction experience at other industrial      '
      facilities (non-nuclear) primarily in California.    The NRC CAT
                            III-9

1

                                       . _ _ - . _      _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ __
         inspectors primary concern in this area relates to the ade-
        quacy of installation of these Class 4 supports. The NRC CAT
        requested SWEC to perform an evaluaticn of inspection report
        results to justify the conclusion that the 20 percent sample
        program provided adequate assurance of proper installation.
        The licensee has not yet completed this evaluation. The small
        number of Class 4 supports / restraints inspected by the NRC CAT
        exhibited no major installation deficiencies.                              However, as
        previously noted, we consider that loose hardware and locking
        devices on Class 4 supports / restraints need additional atten-
        tion.
        In conjunction with the NRC CAT review of design change control
        (Section VII), it was observed that the implementation and the
        FQC inspection acceptance of E&DCR No. T-J-01036 regarding the
        attachment of support identification tags to their respective
        supports were not proper in that the component support name-
        plates which were attached to the supports did not conform to
        the labeling description as required by the E&DCR. Although
        the NRC CAT does not consider this discrepancy to be of major
        significance, it is an additional example of a lack of atten-
        tion to detail by FQC.

c. Conclusions

  In general, pipe supports and restraints were found to be in confor-
  mance to design documents.      However, problems noted with attachment
  locations and beam stiffener sizes indicates a need for clarifica-
  tion of acceptance criteria by SWEC Engineering and more attention
  to detail by SWEC FQC inspectors. The integrally welded attachment
  contact problem indicates that SWEC Engineering evaluations are not
  as complete as may be necessary to ensure that potentially generic
  concerns are identified and resolved for all systems and/or applica-
  tions. The licensee is preparing an evaluation to demonstrate the
  adequacy of-Class 4 support installations which may impact seis-
  mically designed components.      Loose hardware, fasteners and locking
  devices need to be addressed in post-construction inspections. The
  observed drafting errors are considered to be examples of human
  error.

3. Concrete Expansion Anchors a. Inspection Scope

  Ninety-nine concrete expansion anchors on 25 pipe supports /
  restraints and 40 anchors on 10 HVAC restraints were inspected for
  proper diameter, length stamp, embedment, edge distance, damage,
  washers and residual torque (an indication of anchor preload). In
  addition, the length of pipe support expansion anchors were verified
  by ultrasonic testing. The anchors inspected were selected at
  random on a variety of systems and ranged in diameter from one-half
  to one inch. Anchors were torqued to the SWEC specified post
  in3tallation test torque (80 percent of the minimum installation
  torque). Table III-5 provides a listing of the anchors inspected.
                             III-10

1T >  ;

       Acceptance criteria for the field inspections were contained in the
        following documents:
              SWEC Specification M924, " Drilled-In Expansion Type Concrete
              Anchors"
       *
              SWEC Quality Standard, QS-10.43 ML, " Hanger and Anchor Bolt
              Installation / Inspection," Rev. 0
       *
              SWEC Quality Assurance Directive QAD-10.43, " Hangers and Anchor
              Bolt Installation Inspection," Rev. A
    b.  Inspection Findings
       Richmond inserts have been extensively used, thereby minimizing the
       number of concrete expansion anchors. Pipe support / restraint expan-
       sion anchors were installed by SWEC, and HVAC restraint anchors were
       installed by the HVAC subcontractor, Northeast Ventilating Company
       (NEVCO).    Expansion anchor installations were inspected by SWEC FQC
       and included either witnessing of installation torquing or appli-
       cation of a subsequent test torque. Acceptance criteria of the
       Specifications required that, if the anchor nut rotated at less than
       the test torque, the full installation torque must be achieved
       within one turn of the nut for the installation to be acceptable.
       For 19 anchors on pipe supports / restraints and 12 anchors on HVAC
       restraints, nut rotation was observed at less than the test torque.
       Four anchors on the pipe supports / restraints required more than one
       turn to reach minimum installation torque (1-1/2, 1-2/3, 2 and 2-1/4
       turns). All other characteristics examined were either within
       tolerance or had been previously identified and evaluated by SWEC.
    c. Conclusions
       In general, the concrete expansion anchors inspected by the NRC CAT
       were installed in accordance with design and procedural require-
       ments. The results of the torque tests are considered typical of
       normal wedge type expansion anchor installations and do not indicate
       significant installation deficiencies.
    4. Heating, Ventilating and Air Condition (HVAC)
    a. Inspection Scope
       Twelve HVAC seismic restraints were selected at random and inspected
       for location, configuration, member size, weld size and connection
       details. Duct pieces adjacent to the restraints and others
       selected at random were examined for proper attachment to anchors,
       companion angle size and joint makeup. HVAC mechanical equipment
       and concrete expansion anchor installation are discussed in other
       portions of this section. See Table III-6 for a listing of HVAC
       restraints inspected.
       The following documents provided the acceptance criteria for the
       inspection of HVAC hardware installations:

,

                                  III-11

L

                                                                                                                   _ _ _ _ _ _ _ _ _ _ _ _ _    __ __
        SWEC Specification M565, " Installation of Ventilation and
        Air Conditioning Systems," Rev. 7
        SWEC QAD-11.5 ML, " Duct Work Inspection," Rev. A
        NEVC0 Duct Brochure
  *
        Applicable design drawings and change documents

b. Inspection Findings

  Approximately 99 percent of all HVAC restraint (approximately 3100)
  had been installed and approximately 90 percent had been QC
  accepted.
  In general, inspected HVAC seismic restraints conformed to design
  documents and procedural requirements for the NRC CAT selected
  inspection attributes. A minor brace angle discrepancy (two
  degrees out of tolerance) and one minor dimensional discrepancy
  were noted. Duct segments examined were tight, properly attached
  and otherwise conformed to requirements.
  It was noted that the licensee has committed to test Category I, II,
  and III fire dampers under design flow conditions, as discussed in
  letters to the NRC dated February 22, 1985 and March 20, 1985.                                                                             As
  such, fire darrpers were not reviewed during this inspection.
  In conjunction with the NRC CAT review of design change control
  (Section VII), it was observed that the implementation and FQC
  inspection / acceptance of E&DCR FB-33829 regarding the instal-
  lation of a moisture element to ducting were not proper in that the
  overall as-built plate dimensions did not conform to the specified
  dimensions, and that conflicting fastening instructions existed in
  the E&DCR.    This discrepancy is considered to be an example of
  inadequate inspection by FQC.

c. Conclusion

  HVAC restraints and duct segments generally conformed to design
  and procedural requirements.

5. Mechanical Equipment a. Inspection Scope

  Twenty-nine pieces of equipment for ten systems (Chemical & Volume
  Control, Auxiliary Feedwater, Quench Spray, Safety Injection, Safety
  Injection Pump Cooling, Component Cooling, Charging Pump Cooling,
  Service Water, Control Building Air Conditioning and Control Build-
  ing Chilled Water) were inspected for proper configuration, loca-
  tion, condition and bolt size.     Installation documentation for these
  components were also reviewed for content, clarity, consistency and
  thoroughness.    Equipment examined included the Component Cooling
  Water Heat Exchangers, Auxiliary Feedwater Pumps and the Chemical
  and Volume Control Charging Pumps. Table III-7 provides a listing
                            III-12
                                                   _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _
                                                                  ____-___ _- _____

.

    of inspected items.
    The licensee's Preventive Maintenance Program was also reviewed.
    Equipment whose maintenance records were examined for this review
    are listed in Table III-8.
    The following documents provided the basic acceptance criteria for
    the inspections:
    *
          SWEC Specification M914, " Mechanical Equipment Erection," Rev.
          2, Addendum 3
    *
          SWEC Field QC, " Mechanical Equipment Installation Handbook"
    *
          NNECO Procedure MP3704A, " Preventive Maintenance Program,"
          Rev. 0
    *
          SWEC Quality Standard QS-13.12ML, " Material Equipment
          Maintenance," Rev. O
          Applicable equipment details and foundation drawings
 b. Inspection Findings
    Installation inspection reports exhibited proper sequencing of
    inspection. The NRC CAT inspector examined documentation for
    components which were considered to be completely installed, and
    those which were still in process.      Equipment which had received
    final alignment and/or whose foundation anchor bolts had been
    tensioned or torqued were considered to have been completely
    installed.
    Of the 29 components for which installation documentation was
    reviewed, all had been inspected and found acceptable by FQC for
    those attributes examined by the NRC CAT inspector. Of these
    components, the NRC CAT identified discrepancies between
    installation requirements and as-installed conditions for 19
    components.
    1.    The following components did not possess documentation
          which indicated that their foundation bolting was torqued
          to the requisite values specified by the vendor drawing:
          *
              Quench Spray (QSS) Pumps                    (P3A,P3B)
          *
          *
              Charging Pump Cooling (CCE) Pumps           (P1A,PIB)
              Safety Injection Pump Cooling (CCI) Pumps (P1A,PIB)
          *
              Service Water (SWP) MCC & Rod Area
          *
               Booster Pumps                              (P3A,P38)
              Control Building Chilled Water (HVK) Pumps (P1A, PIB)
    2.    The following components were missing washers at all
          foundation anchor locations, contrary to drawing and
          Specification requirements:
                               III-13
                                 _
                                                                    _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
     *
         Chemical & Volume Control (CHS) Charging
     *
          Pumps                                      (P3A,P38,P3C)
         Auxiliary Feedwater (FWA) Pumps             (P1A, P1B, P2)
     *
         Quench Spray (QSS) Pump                     (P3A)
     *
     *
         Safety Injection Pump Cooling (CCI) Pump    (P1A)
         Service Water (SWP) MCC & Rod Area          (P3A,P3B)
          Booster Pumps
     *
         Control Building Chilled Water (HVK) Pumps (P1A, PIB)
     Boric Acid Transfer Pump CHS*P2A was observed to be missing                                        ,
     two washers and CHS*P2B was missing one washer at their
     respective foundation anchor attachments.

3. The following components were installed without the specified

     double nut arrangement on the foundation anchor bolts:
     *
     *
         Safety Injection (SIH) Pumps                (PIA,PIB)
     *
         Quench Spray (QSS) Pumps                    (P3A,P38)
         Auxiliary Feedwater (FWA) Pumps             (P1A,P1B,P2)

4. Boric Acid Tank CHS*TK58 was found to have nearly all of its

     foundation anchor nuts loose, despite a SWEC FQC inspection
     report verifying their tightness.    It was learned that this
     component had been transferred to NNEC0 responsibility.
     However, NNECO at the time did not possess documentation
     authorizing work on this component, nor were they aware of
     the component's condition. NNEC0 did not have a formalized
     procedure in place which verified the acceptability of equip-
     ment conditions, protective measures, and surroundings. As a
     result of the NRC CAT observations, the licensee performed
     a reinspection of approximately 80 Seismic Category I compo-
     nents (all mechanical equipment including HVAC) in order to
     verify compliance to specified anchorage criteria. Several
     additional discrepancies were identified. All discrepancies
     whether identified by the NRC CAT or by the licensee were
     documented on UNSAT Inspection Reports with corrective actions
     to be implemented.

Eight components were found to have been installed to the specified requirements, and are appropriately noted in Table III-7. The NRC CAT inspectors also reviewed the seismic analyses for the Auxiliary Feedwater Motor Driven and Turbine Driven Pumps, Quench Spray Pumps, Safety Injection Pump Cooling Pumps, Charging Pump Cooling Pumps and the Service Water MCC and Rod Area Booster Pumps for consistency between the foundation anchor bolt material type assumed in the analyses, and the as-installed material. No discre- pancies were identified. The seismic analyses for components supplied through Westinghouse, e.g., CVCS Charging Pumps and Safety Injection Pumps were not available for review. With regard to the review of the Preventive Maintenance Program, fornal maintenance records for the 25 components selected for this review were available and complete until the time the components were turned over to NNECO from SWEC. No discrepancies were identi-

                           III-14
                                                                           _ _ _ _ _ .
   fied in the SWEC maintenance records.    However, formal records
  of mechanical related activities for 23 components did not exist for
   the time period between " turnover" and Phase 1 preoperational
   testing (the exceptions being the periodic maintenance performed on
   the Service Water Pumps).     The NRC CAT was concerned that preventive
  maintenance activities had not been performed on those pieces of
  equipment which experienced extended delays between turnover and
  Phase 1 testing, and that if maintenance activities had occurred, a
  means of verifying the performance of activities through formal
  documentation had not been established. This similar concern had
  been expressed in a December 28, 1984 NUSCO QA Audit A-40958.
   In response to our concerns, NNECO proposed changes to Maintenance
  Procedure 3704A, " Preventive Maintenance," which would include
  formalized review and implementation guidelines regarding storage
  preventive maintenance activities, and an evaluation of the effects
  of missed maintenance activities over two or more periods. Main-
  tenance Procedure 3719MB, " Mechanical Equipment General Inspections"
  was to be written also to document inspection criteria for mechani-
  cal equipment.    In addition, equipment which have already been
  turned over to NNEC0 will be reviewed for inclusion into the Pre-
  ventive Maintenance Program in accordance with the revised proce-
  dures. These proposed changes, when implemented, will adequately
  resolve the concerns of the NRC CAT.

c. Conclusions

  No major hardware discrepancies were noted during the inspection of
  mechanical equipment.    However, the NRC CAT inspectors are concerned
  that final configurations for foundation aachor attachments are not
  receiving adequate inspection to ensure their conformance to speci-
  fled requirements. Although the licensee has performed a reinspec-
  tion of all Category I mechanical components, additional attention
  in the programmatic and procedural areas is warranted since future
  inspections resulting from modifications, rework, and maintenance to
  these components will likely be necessary.
  The NNECO Preventive Maintenance Program was deficient in that
  formal measures were not implemented to ensure continued maintenance
  activities for components prior to preoperational testing.     Changes
  to the program have been proposed to resolve this deficiency.
                             III-15
                                                                . _ .       _ _ _ _ _ __ _ _

7

                            TABLE III-la
                PIPING INSPECTION SAMPLE (Large Bore)
        Drawing   Diameter       Pipe
 System Number    (Inches)       Class   Observations                 Notes
 CHS    CHS-11      3               2    None                         1, 2
        Sheet 2
        Issue 7
 CHS    CHS-31    3/4, 3, 4         2    Clearance violation
        Sheet 3                           (7/8") at pipe sleeve
        Issue 5                          not identified
                                         Drafting errors at PLI         4
                                          include: omitted
                                         dimension, omitted
                                         support function and
                                          identification, and
                                          incorrect pipe
                                         orientation angle (4 )
 CHS    CHS-32    3/4, 3, 4         2    5'4-13/16" design              3
        Sheet 3                          dimension measured
        Issue 6                          approx. 4'7"
                                         l'2-9/16" design               3
                                         dimension measured
                                         approx. 12"
 CHS    CHS-45      3               3    9'4-7/16" design               1
        Sheet 3                          dimension measured
        Issue 6                          approx. 9'3"
                                         7'6-1/16" design
                                         dimension measured
                                         approx. 7'7/12"
 FWA    FWA-1A     10               3    2'2-1/2" design
        Sheet 3                          dimension measured
        Issue 3                          2'5-1/2"
                                         Support PSR 193              3, 5
                                         design location is
                                         4-1/16" north of
                                         branch to valve V954;
                                         Actual location is
                                         3-1/2" south of the
                                         branch
                              III-16
                     TABLE III-la (Continued)
              PIPING INSPECTION SAMPLE (Large Bore)
      Drawing   Diameter        Pipe

System Number (Inches) Class Observations Notes FWA FWA-2 8 3 2'2-15/16" design

      Sheet 3                              dimension measured
      Issue 2                              approx. 2'7"
                                          3'11-1/8" design
                                          dimension measured
                                          approx. 3'9"
                                          3'3 15/16" design
                                          dimension measured
                                          approx. 3'0.

FWA FWA-2 8 3 l'11-11/16" design 3

      Sheet 4                             dimension measured
      Issue 2                             approx. 2'11"

FWA FWA-3 10 3 None

      Sheet 4
      Issue 4

FWS FWS-13 16, 18, 20 2, 3 None

      Sheet 4
      Issue 3

FWS FWS-13 8, 18, 20 2 None

      Sheet 5
      Issue 3

RHS RHS-1 8, 10 2 None 2

      Sheet 5
      Issue 5

RHS RHS-1 10 2 None 2

      Sheet 6
      Issue 5

RHS RHS-501 1, 4, 12 1, 2 l'2-13/16" design 1, 2

      Sheet 3                             dimension measured
      Issue 7                             approx. 12"

RHS RHS-501 12 1 1

      Sheet 4
      Issue 7
                             III-17
                                                                                                                                        ,

r

                                 TABLE III-la (Continued)
                           PIPING INSPECTION SAMPLE (Large Bore)
             Drawing         Diaraeter       Pipe
   System    Number          (Inches)        Class     Observations                                                           Notes
   QSS       QSS-3           6,-8, 12          2       3'6-7/8" design
             Sheet 4                                   dimension measured                                                              '
             Issue'4                                   approx. 2'6"
                                                       Support (PSR-063)
                                                        identified as vertical
                                                       and axial restraint
                                                      only.                                     Also provides
                                                       lateral restraint
                                                      3'8 5/8" design
                                                      dimension ncasured
                                                      approx. 3'6"
                                                      4'2-1/4" design
                         7                            dimension measured
                                                      approx. 3'6"
                                                                                                                                       ,
   SIL       SIL-8         8            2             Clearance violation                                                       1
 <
             Sheet 5                                   (3/4") between valve
             Issue 6                                  and adjacent pipe
                                                      no. 3-DGS-002-62-4
                                                      not identified
   CHS - Chemical & Volume Control
   FWA - Auxiliary Feedwater
   FWS - Feedwater
   QSS - Quench Spray
   RHS - Residual Heat Removal.
   SIL - Low Pressure Safety Injection
                                          III-18

, ,

                                                      _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ - ,       -
   _ _ _ _ _ _ _ _ _ _ _ _ _                       _ _ _ _ _ ._.        .            _ _ _ _ _ _ _ _ _ - _ - _ _ _                - _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _ ___ _ __
                                                                                                                                                                                             ,
                                                                   TABLE III-lb
                                           PIPING INSPECTION SAMPLE (Small 8 ore)
                               Drawing          Diameter                       Pipe

System Number (Inches) Class Observations Notes SWP 319702 2. 4 None 1

                               Sheet 3
                               Issue 5

SWP 319703 2 3 None 1

                               Sheet 4
                               Issue 5

SWP 319722 1 3 None 1

                               Sheet 3+
                               Issue 3

SWP 319728 1 3 Clearance violation 1

                             . Sheet 4                                                                               (5/8") between pipe
                               Issue 5                                                                               and adjacent pipe

SWP 319729 1 3 None 1

                               Sheet 3
                               Issue 5
                                                                                                                                                                                             ,

RHS 371003 2 2 2'6" design dimension

                               Sheet 3                                                                               measured 2'8"
                               Issue 6

RHS 371702 3/4 2, 4 None 1

                               Sheet 3
                               Issue 6

CCE 410100 1-1/2, 2 3 None 1

                               Sheet 3
                               Issue 6

CCE 410511 1-1/2, 2 3 None 1

                                                                                                                                                                                             '
                             . Sheet 3
                               Issue 6
                                                                                                                                                                                             i

CCE 410512 2 3 l'10-7/8" design 1

                               Sheet 3                                                                               dimension measured
                               Issue 5                                                                               approx. 2'0"

CCE - Charging Pump Cooling RHS - Residual Heat Removal < SWP - Service Water

                                                                      III-19
_                                       __ -, .                  _   . . _ . . _ _ ,                               .     _ _ _ _ _ _ . .._ __                                 .       ,
                                                                                                                                                                                        _
                                                                                                                                                                                          _.
                                                                                                                                           . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___
                                                                                                                                                                                                 t
                                                                                    TA8LE III-lb (Continued)
                                                                   PIPING INSPECTION SAMPLE (Small Bore)

!

             NOTES:
             1.   Pre N-5 final inspection was complete for this isometric.
             2.   This piping was partially or completely insulated at the time of the NRC CAT
                  inspection.

l 3. This dimension was to " moveable" (i.e., other than integrally attached) ,

support and will be remeasured during pre N-5 inspection. i
             4.   This error would likely be detected during the as-built stress                                                                                                               f

'

                  reconciliation effort.                                                                                                                                                       '
             5.   This error might be detected during the ASME III Fabrication / Installation
                  not yet performed.
                                                                                                                                                                                                ;

l ! !

! !

                                                                                                                                                                                               f
                                                                                                                                                                                                ,
                                                                                                                                                                                                *
                                                                                                                           .
                                                                                                                                                                                                ;
                                                                                                                                                                                               ;
                                                                                                                                                                                               e
                                                                                                                                                                                               t

i l I l l l III-20 ! !

 , _ - - _ .        . , - _ _ _ , , , _ , _ _ - _ . . _ _ _ _ . _ , _ _ _ - _ _ . . _ _ , . _ _ , _ . , _ , . . _ _
                            _                                                                                        . _ _ _ _ _ - - - . _ . . _ , . , _ _ . _ - _ _ _ _ , , - - -
                                                                                _ - _ _ _ _ _ _ _ _ _ - _ _ .
                                         TABLE III-2a

l HYDROSTATIC / PNEUMATIC TEST PACKAGE SAMPLE

              Isometric Package                               Isometric Packene
                   CHS-5                                           QSS-6
                   CHS-25                                          QSS-22A
                   CHS-54                                          QSS-30                                     1
                   CCP-151                                         QSS-800
                   CCP-269A                                        QSS-801
                                                                                                              '
                   FWA-13                                          QSS-802
                   FWA-800                                         QSS-803                                    ,
                   SIL-12                                          QSS-804
                   SIH-7                                           RHS-3
                   SIH-46A                                         RSS-9
   CHS - Chemical & Volume Control
   CCP - Component Cooling Water
 ~ FWA - Auxiliary Feedwater
   SIL~ - Low Pressure Safety Injection
 'SIH - High Pressure Safety Injection
 . QSS - Quench Spray                                                                                         ,
   RHS - Residual Heat Removal
  RSS - Containment Recirculation Cooling

l t !

                                            III-21
                                                                                                              ,
 .      . _ _ _ _      _.     _ _ _ _ - .              _ _ _

r

                                            TABLE III-2b
                            PIPE WALL THICKNESS SAMPLE AND OBSERVATIONS
                                                             Specified Nominal  Minimum Wall

l Manufacturer / Pipe Size / ASME (Minimum) Wall Thickness Measured

      (Heat No.)            Schedule        Class            Thickness (Inches)      (Inches)
                                                                                                   r
    B&W(67292)              6/160            2               0.718 (0.629)           0.730
    PSC (62886)             10/XS            2               0.500 (0.438)           0.475
    A-T (08169)             1/160            1               0.250(0.219)            0.232         !
                                                                                                   !
      S (455674)            2/160            1-              0.343 (0.300)           0.317
                                                                                                   '
    B&W(M4865)              2/80             2               0.218 (0.191)           0.194
    B&W(M3890)              8/160            2               0.906 (0.793)           0.898
    C-W (2561-1-2)'         12/160           1               1.312 (1.148)           1.252
    A-T - AL Tech Specialty Steel Corp.
   -B&W - Babcock & Wilcox Tubular Products Division
    C-W - Curtiss-Wright Corp.
    PSC - Phoenix Steel Corp.
    S        - Sandvik Inc.
                                                III-22
                                                                     _      ._. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ ___ - __ _ __ _
   .
                                              TABLE III-3
                              PIPE SUPPORT / RESTRAINT INSPECTION SAMPLE
                                                     Pipe              Size
          S/R Number               Tyge             Class          (Inches)                         Location
         CDS-1-PSST-227            Strut               4                4                         Annulus
         CCP-1-PSR-154             Strut               3                4                         Annulus
         CCP-2-PSRH-175            Rod                 4                2 1/2                     Aux.
         CCP-2-PSR-069             Strut               3               18                         Aux.
         CHS-2-PSR-324             Box                 2                8                         Aux.
         CHS-2-PSSH-020            Spring              2                4                         Aux.
         QSS-1-PSSP-407            Snubber             1               12                         Cont.
         QSS-4-PSSH-050            Spring              4               12                         Cont.
         QSS-4-PSST-115            Strut               2               14                         ESF
         RCS-1-PSA-037             Clamp Anchor        1                4                        Cont.
         RCS-1-PSSP-522            Snubber             1               14                        Cont.
         RCS-1-PSSH-524            Spring              1               14                        Cont.
         RCS-1-PSSH-500            Spring              1                8                        Cont.
         RCS-1-PSR-025             Strut               1                4                        Cont.
         RHS-1-PSST-009            Strut               1               12                        Cont.
         RHS-1-PSST-011            Strut               1               12                        Cont.
         RHS-1-PSR-014             Strut               2             12                          Cont.
         RHS-1-TPSR-072            Bolted Clamp        1            3/4                          Cont.
         RHS-4-PSSP-413            Snubber             2             10                          ESF
         RSS-1-PSA-079             Box                 2             10                         Cont.
         RSS-1-PSR-106             Strut               2             12                         Cont.
         RSS-1-PSSP-434/435        Snubbers            2             12                         Cont.
         RSS-4-PSRH-047            Rod                 4             10                          ESF
         RSS-4-PSRH-053            Rod                 4             12                         Cont.
         RSS-4-PSSH-141            Spring              2             10                         Cont.
         RSS-4-PSST-002            Strut               2                8                       Cont.
         SIL-1-PSR-358             Strut               1                6                      Annulus
         SIL-1-PSA-446             Clamp Anchor        1                6                      Annulus
         S!H-1-PSR-349             Strut               2                4                      Annulus
         SIH-4-PSST-105            Strut               2                4                       ESF
         SWP-4-PSST-117            Strut               3             18                         ESF
         SWP-4-PSA-142             Bolted Anchor       3                8                       ESF
         Annulus - Containment Building Annulus
         Aux.    - Auxiliary Building
         Cont.   - Containment Building
         ESF     - Engineered Safety Features Building
                                                 III-23

L _ _ . .

                                      TABLE III-4
                   PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS
                                    Primary Sample

Support / Restraint Observation QSS-4-PSST-115 Oversized strut installed (N&D 11,574).

                                           Drafting error-failure to correctly
                                           incorporate weld size (N&D 11,506).

SIL-1-PSA-446 Draf ting error-failure to correctly

                                           incorporate weld symbols (E&DCR T-J-03609).

SIH-1-PSR-349 Strut rod end bearing spacers missing

                                           (PLIR 1298).

RCS-1-PSSH-500 Attachment location 1-1/2 inch from

                                           location indicated on drawing.
                                           Weld of Pc. 9 to existing steel not
                                           centered as shown on dwg. sect. 2-2.

RCS-1-PSSH-524 Orientation of lugs approx. 30 degrees

                                           from that specified on dwg. Note 4.
                                           (N&D 11,708).
                                           Elevation attachment locations of Pc, 8
                                           and 9 to embed 2-1/2 to 3-1/2 inch from
                                           that shown on dwg.
                                           One cotter pin not bent.

RSS-1-PSA-079 Improper structural bolts installed;

(Not yet final QC accepted)                removal of stiffener plates required for
                                           rework (IR P5A91133).

RSS-1-PSR-106 Loose locknut. RHS-1-PSST-009 Attachment location 2 inches from that

                                           shown on dwg. (IR P5A91143).
                   '
                                           Drafting error-failure to incorporate
                                           weld symbols (N&D 11499).
                                           Loose locknut.

SWP-4-PSST-117 Attachment location 24 inches from that

                                           shown on drawing.
                                        III-24
                               TABLE III-4 (Continued)
                   PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS
                                    Primary Sample

Support / Restraint Observation CCP-1-PSR-154 Weld of Pc. 6 to existing steel is welded

                                            across the beam flange; Section 2-2 of
                                            dwg. shows it welded along the run of the
                                            beam (N&D 11,711).
                                            Stiffener plates lack 5/8 inch from
                                           extending full width of flange (N&D
                                            11,900).
                                           Unspread cotter pin.

RCS-1-PSR-025 Attachment location of Pc. 2 rear bracket

                                           2-1/2 inches from that indicated on dwg.
                                           (N&D 11,709).

QSS-4-PSRH-053 Loose rod

  (CAT II)
                                           Lockwasher installed on Hilti anchor (N&D
                                           11,657).
                                           Anchor spacing violation to adjacent
                                           support (that had not yet been QC
                                           accepted) (N&D 11,557).
                            Adjacent Supports / Restraints

Support / Restraint Observation RSS-1-PSR-114 Sheared cotter pin, pipe clamp out of

                                           adjustment.   (IR P3003277).

RCS-1-PSST-429 Clamp and bearing spacers missing. RHS-4-PSST-001 Strut not tight, tapered bearing washers

                                           installed backward.

RHS-4-PSSP-410 Strut locknut backed off. SIH-1-PSA-342 Clamp anchor loose, missing flat and lock

                                           washers, weld undersized and poor quality
                                           (IR P549129).
                                        III-25
                                                                                                       _ _ __
                                       TABLE III-4 (Continued)

l PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS

                                 Ad.lacent Supports / Restraints
 Support / Restraint                                                            Observation
 DAS-2-PSRH-416                                             Loose pipe clamp, loose rods with
   (Cat II)                                                 inadequate thread engagement, riser clamp
                                                            not in contact with lugs (IR P5A91559).
 SFC-1-PSRH-113                                             Cotter pins not bent.                             -
 DFR-4-PSR-001                                              Box restraint has zero clearance top
   (Cat II)                                                 and bottom (IR PSA91560).
 MSS-1-PSSH-128                                             Only one lug in contact with riser
                                                            clamp.         Design calculation is based on
                                                            load being carried by two lugs.
                                                                     .
                                                                           E
                                                                                        s
                                                                                 W
                                                       ,
                                                                  :
                                                              e
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                                                                                      '
                                  & O
                                                                                          *
                                                                                              )               ,
                                    #'
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                                                                    / .,
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                                                                                 I          .
                                                                                                >
                                                 .
                      /
                                                          '
                                                  ./        ,                -\
                                               ,
                                                 -
                                                       III-26
                                        '
                            ,
                                          ,.
                                             <       -
                                                                                ,.; '             ,
             ;,          ..

C

                                      TABLE III-5
                           CONCRETF EXPANSION ANCHOR SAMPLE
                               Pipe Supports / Restraints
                    Number-Diameter                         Number-Diameter
                      of Anchors                              of Anchors
  Pipe Support          Inspected          Pipe Support         Inspected
 CP408052-H003            2-3/4"           RSS-4-PSR-190          4-1"
 CHS-2-PSSH-209           2-1"            CP41022-H001            2-1"
 BDG-1-PSSP-430           3-3/4"          CP319732-H001           2-3/4"
 CP408056-H002            4-3/4"          CH-2-PSR-354            4-1"
 CP408056-H004            3-3/4"          CCP-2-PSR-125           4-3/4"
 CP408056-H005            3-1/2"          CCP-2-PSSP-401          4-3/4"
 CP405001-H003            2-3/4"          SIL-2-PSA-287           13-1"
 CHS-1-PSR-549            6-1"            SIH-2-PSA-191           4-1"
 QSS-4-PSSP-400/407       2-1"            SIL-2-PSR-283           4-3/4"
 CCP-4-PSR-113            3-1"            CHS-2-PSSP-468          4-1"
 CP394038-H001            4-3/4"          CHS-2-PSA-353           8-1"
 CPS 26022-H002           2-1"            RSS-4-PSSP-412          4-1"
 RSS-4-PSST-140           4-1"
                                    HVAC Restraints
                    Number-Diameter                         Number-Diameter
                      of Anchors                              of Anchors
 Restraint             Inspected                Restraint      Inspected
 DSA-1321                 4-1"                  DSA-785           2-1"
 DSA-1172                 6-1"                  OSA-948/950       6-1"
 DSA-812                  4-1"                  DSA-1250          2-1"
                                       III-27

m

                                                                                  -
                ,g:-       l,t
                                                                                                  .
                                           TABLE III-5 (Continued)
                                                                                                s
                                                                                          "
       ' .       ,
                                      CONCRETE EXPANSION ANCHOR SAMPLE              .
          '
                               _
                                               HVAC Restraints.
                                                                          5
                                                                '
                                 Number-Diameter .                     Number-Diameter

                                  Lof Anchors                            of Anchors
                      Restraint.    Inspected              Restraint      Inspected
          I          'DSA-863-        3-1"                 DSA-1251          2-1"
                      DSA-1240        3-5/8"              'DSA-431          5-1"
                                      1-1"
     ,
       ~
                      DSA-758-        2-1"
                                                                                        ,
                                                                                      9
                                                                                              s
              T
                                                                                            W
        g
  ..
     + ,,
                           e
            4

%

 .                                                 III-28

( .- -

                                                       ,
                                                                                 ,
 p_
                                                            TABLE-III-6
            ,
                                     . HVAC INSPECTION SAMPLES AND OBSERVATIONS
                                                         Suports/ Restraints
              Support / Restraint                Location                                  Observations
                                  s                                        *
                    DSA 314                     -Aux. Bldg.                          Acceptable
                    DSA 016                      Aux. Bldg.                          Acceptable
                    DSA 1209                     Aux. Bldg.                          Acceptable
                    DSA 1210*                  ' Aux. Bldg.                          Acceptable
                    DSA7q8                       Aux. Bldg.                          Acceptable
                  .
                    DSA 1211                     Aux. Bldg.                          Acceptable
                 -DSA 464            '
                                                 Aux. Bldg.                          Brace angles exceed dwg.
                                                                                     tolerance by 1 and 2 degrees.
                                                                                     (No structural significance.)
                    DSA 1166                    Aux. Bldg.                           Acceptable
               i
                    DSA'1167                    Aux. Bldg.                           Extension of vertical member
                                                                                     past brace was 3-1/2 inches.
                                                                                     Dwg. shows 1 inch.           (No
                                                                                     structural significance.)
                   DSR 277                       ESF Bldg.                           Acceptable
                   DSA'278                      ESF Bldg.                            Acceptable

'

                   DSA 403                      ESF Bldg.                            Acceptable
      r.
                                   v
                                        @
                                                              III-29
    _
                                          u ,    _.m.,            .,-.,um-   -,- -,m  _~         ,e -. -e.-e. r.,
                                                                                                                    9 ,. .- -g ,m-p

p ,

   91                                         TABLE III-7
                                      MECHANICAL EQUIPMENT SAMPLE
              Equipment                                                       Acceptable *
        Chemical & Volume Control Charging Pumps         CHS*P3A, P38, P3C
        Auxiliary Feedwater Pumps                        FWA* PIA, PIB, P2
        Refueling Water Recirculation Pumps.             QSS*P1A,PIB              .X
       . Quench Spray Pumps'                            -QSS*P3A,P3B
  '
 - '-
      . Safety Injection (SI) Pumps                      SIH*P1A, PIB
       .SI Pump Cooling Pumps                            CCI*P1A, PIB
      . Boric Acid Transfer Pumps                        CHS*P2A, P2B
        Volume Control Tank                              CHS*TK2                   X
        Boric Acid Tank                                  CHS*TK5A                  X
        Boric Acid Tank                                  CHS*TK58
        Component Cooling Heat Exchanger                 CCP*ElB                   X
        Charging Pump Cooling Pumps                      CCE*P1A, P1B
      -Charging Pump Cooling Surge Tank                  CCE*TK1                   X
       : Service Water MCC & Rod Area Booster Pumps      SWP*P3A, P3B
       ' Engineered Safety Features Air                  HVQ* ACUS-1A,1B           X
          Conditioning Units
        Control Building Chilled Water Pumps
                          _
                                                         HVK*P1A, PIB
        * Note: All components were observed having installation deficiencies
                 unless stated as " acceptable."
                                                 III-30

m

tr- ,

                                 :s
               _
f:               t -   -
                                                           ~ TABLE III-8
                                             PREVENTIVE MAINTENANCE EQUIPMENT = SAMPLE
                                 Equipment
                           Boric Acid-Transfer Pumps-                           CHS*P2A, P2B

,

        -.
                         . ESF. Building-Ventilation Fan'                       HVQ*FNSA

,, Spent Fuel Cooling Pumps. SFC* PIA, PIB

                         , Quench Spray Pumps-                                  QSS*P3A,P3B
                         - CVCS Charging Pumps-                                 CHS*P3A, P3B
                          Diesel; Generator Building Ventilation Fan            HVP*FNIC
                          Auxiliary.Fsedwater Pumps                             FWA*P1A, P1B, P2
                          Residual Heat Removal Pumps                           RHS* PIA; PIB
                          Diesel Generator Fuel Oil Pumps'                     .EGF*P1A, P1B, Plc, PID,
                          Service Water Pumps.                                  SWP*P1A, PIB

4

                          Safety Injection Pumps                                SIH*P1A, PIB.
                     '
                          Contro1' Building Chilled Water Pumps                .HVK*P1A, PIB
                  .
                           t
           D
               N             -
             9
                  %
     -N
     ,
   -
                                                              III-31
         1
 ,
     -IV.  WELDING AND NONDESTRUCTIVE EXAMINATION (NDE)
           A. Objective
              The objective of the subject appraisal was to determine the licensee
              effectiveness and program adequacy in controlling and performing activi-
              ties in accordance with the Final Safety Analysis Report (FSAR) commit-
              ment, design requirements and applicable codes and standards. An addi-
              tional objective was to determine if the personnel involved in welding
              and NDE activities were adequately trained and qualified to perform
              their duties in accordance with applicable specifications, codes and
              standards.
          .B. Discussion
              A detailed inspection of welding and NDE activities was conducted.     This
              inspection included welds in both ASME Code and AWS Code related areas.
              The ASME Code area included piping, pipe supports, and pressure vessels.
              The AWS area included electrical, instrumentation and HVAC. supports,
              structural beam clip welds, component cooler beam stiffener support
              welds, refueling cavity liner welds, fire protection pipe support welds,
              HVAC duct welds, and refueling cavity support stand welds. The NDE
              portion of the inspection included review of site and vendor radiographs,
              NDE procedures, observation of FQC inspectors in the course of NDE
              examinations and review of NDE equipment calibrations.
              The inspected welds were representative of the licensee's site _ welding
              and vendor supplied equipment in terms of welding processes used,
              materials welded, various welding craft conducting welding operations
              and existing weld-joint configurations.
              During the inspection of NDE activities, the NRC Construction Appraisal
              Team (CAT) inspectors reviewed samples of current radiographic film and
              radiographic film in final storage in the vault at the licensee's
              facility.    In addition, the NRC CAT inspectors reviewed samples of film
              which was stored at vendor facilities which was made available for this
              inspection. No significant problems were identified in the area of
              field and shop welding and NDE activities. However, several discrepan-
              cies were identified in the areas of field and vendor NDE, and detailed
              discussion concerning these discrepancies is included later in this

>

              section.
              The welding and NDE activities were examined in order to ascertain
              compliance with the governing construction codgs and specifications.
              This effort involved the review and inspection of the following areas
              and contractors:
              Field Fabrication and Contractors
              Field fabrication of piping and pipe supports (Main Steam, Reactor
   *
              Coolant, Feedwater, and Safety Injection) - Stone and Webster
              Engineering Corporation (SWEC)

i

                                              IV-1

!~ >

                                                                                - ,-

F

 Electrical install tion and electrical supports - SWEC
 Instrumentation tutIng installation and instrumentation supports - SWEC
 Heating, Ventilatics and Air Conditioning installation and supports -
 Northeast Ventilation Company (NEVCO)'
 Structural steel fabrication and erection - SWEC
 Fuel storage pool and refueling cavity liner fabrication - PX Engineer-
 ing shop fabrication and SWEC installation
 Mechanical equipment installation - SWEC
 Fire protection system fabrication and installation - SWEC
 1.  Piping
 a.  Inspection Scope
     The NRC CAT reviewed activities related to fabrication and SWEC
     installation of piping fabricated by TUBECO and Southwest Fabrica-
     ting and Welding. These activities included visual inspection of
     welds, welding procedures and welder qualifications documentation.
 b.  Inspection Findings
     Detailed visual inspection was performed on portions of the Reactor
     Coolant loop piping, Feedwater, Main Steam, Safety Injection and
     other seismically designed piping. Approximately 800 large diameter
     butt welds and 600 small diameter socket welds were inspected. See
     Tables IV-1 and IV-2 for details. In addition to visual inspection,
     the items listed in Table IV-2 were reviewed for correctness and
     completeness of documentation.     During this review, special atten-
     tion was given to verifying that the required nondestructive exami-
     nation had been performed, that the materials used met tensile and
     impact test requirements, and that SWEC welders were properly quali-
     fied at the time the welds were made. In addition, six SWEC welding
     procedures which were widely used on piping systems were reviewed.
     During the visual inspection of the piping welds, no unacceptable
     welds were observed.     During the review of documentation of those
     items listed on Table IV-2, it was observed that one butt weld had
     been allowed to cool at a rate in excess of that permitted by Code.
     N&D 11791 was generated to address this finding. It was also
     observed that there were code-related editorial errors on three of
     the Welding Procedure Specifications which were reviewed. E&DCRs
     41852, 41853 and 41854 were generated to address these observations.
     During documentation review, the NRC CAT reviewed approximately 180
     welder qualification records for eighteen welders, and verified that
    - each welder had remained qualified from the date of his original
     qualification to the date that he welded, as recorded in the docu-
     mentation.
                                  IV-2
                  , .                        -.- -                                                  .-       ..              -                 -.                                   .            .
    '                '
                         ,   .

.

                                                              '
                                                                        ,
                                                                                                                                                     - .
                                                                                                                                                                               ,

.

                                                            No' : problems were identified in the' area of- inspected welding activi-
                                                            ties.                                                                                                                                    .
                                                                                                                                                                                                     i

. .

 ,
                                                   - c.     Conclusions
        *
                                                           With'the exception.of the e'ditorial erro's                 r in three welding
                                                          . procedures and excessive cool down rate involving one weld...the                                                                         ;
                                                            inspected piping welds'were found to' comply with the applicable
                                                            codes and standards,
i
                                                    2.     -Tanks, Pressure Vessels and Heat Exchangers
                                                    a .' . Inspection Scope
                                           ~

c

                                                         ~The.NRC CAT reviewed-activities related to the fabrication of twelve
            -
                                                         -tanks,1 pressure vessels and heat exchangers manufactured by various
i-                                                         vendors as shown in Table IV-3. These activities included visual:

>

                                                            inspection of' completed welds, including ASME pressure boundary and

. -

                                                           support; welds.
                                                   ~ b.     Inspection Findings
                                                          .0ffthe. twelve,.one tank was found:to be acceptable, three had under-
                                                                                                                     -
,                                                          sized welds on supports only, eight'had undersized welds on nozzles,.

<

                                                           manways'and supports,.and one had an unacceptable weld surface con-
                                                           dition. These-items were identified for resolution by the N&Ds
                                                            listed on Table IV-3.
                                                         . Based'on the'NRC CAT findings-regarding the support welds,.a Report
                                                         fof a' Problem (ROAPL 85012 was issued and an additional52 vendor

i: supplied Category I tanks, pressure vessels :and heat exchangers

                                                           were-inspected by SWEC. Of these, 32 had fillet welds' undersized by,
                                                           one-sixteenth to one-eighth inch. . MMDs were written to cover 14 of

[ these items prior to the end of the inspection. SWEC indicated that

                                                           they.would inspect all nozzle and manwayLjoint configuration fillet ~
                                                                                                                             t
                                                         : welds on Category I tanks, pressure vessels and                                  heat exchangers and
                                                                                                                                                                                                     "

C

                                                           issued ROAP 85008-to accomplish this task.

1

                                                    c.     Conclusions
             ,
                                                                                                  ~

-

                                                           With the exception-of the identified deficiencies involving under--
sized fillet welds in supports,:in nozzles and manways on ASME Code -
                                                           fabricated tanks and heat exchangers, the tank and heat exchanger
      ~

,

                    ,                                      welds were found to comply with applicable codes and standards.
                                                                                                                                                                                                     ,
                                                    3.-~ Piping Supports and Restraints

l: -

                                                    a.     Inspection Scope.

.

                                                           The NRC~ CAT-reviewed activities related to fabrication and instal-

,

                                                           lation of' piping supports and restraints manufactured by Corner'and
                                                           Lada and. supporting steel installed by SWEC. These activities
                                                           included inspection ~of welds and general configuration of supports
and res',raints.
                       .
                           .
IV-3
        -                                                                                                                                                                                            !

,

.m'
 -
                                                                                 ,--,-,--,,U.n#w.
                                                                     '
       n       e+              -- , - . , .                     ,,,-.E-   ., , ,                       m,,-.    4y-,      . . . , - , - - ,       ,y  4  ~ e v E,e , ~ m , y r ,+, ,  +-v+--~,w-   u
                    ..
        i
                               'b. ' Inspection Findings

-

                       -
                                      A sample.of-35 supports and restraints was selected based on con-
                                       figurations-whose complexities-provided fabrication difficulties.
                                      These; supports were:then visually inspected for weld size and
                                      appearance to determine conformance to engineering drawing require-
   -
                                      ments. The supports examined are shown in Table IV-4 and. included
               '
                                 - .approximately 400 welds. -A large number of skewed joint fillet
                                     . welds were found by the.NRC CAT inspectors to be undersized on the
                                      obtuse-angle side.of the connection. .No undersized welds were dis-
                    *
                                      covered on the'. acute side'of such connections. A second problem was
                                     . observed when the. skewed angle exceed 135*.   In this case the engi-
                                      neering drawings required that the toe of one of the members being
                                      joined be cut back so that the required fillet weld size could'be
          0
                                     ~obtained. Two cases were identified in which the member had been
                                     _inadaquately cut back and did not produce the required fillet weld
                                      size. As'a. result of the NRC_ CAT. findings, SWEC inspected 80 addi-
                                      tional skewed configuration supports and found 41 supports which had
                                      undersized fillet welds on the obtuse angle side.
                                      SWEC analyzed the skewed connections generically for connections
                                      welded on the heel (acute angle side) and two sides, taking_no
                                                 -
   '
                                    : credit;for any weld which might be~on the toe of the connection.
                                      Calculation 12179-NP(F)-4046-ZC demonstrated that as the connection
             ,                        angle becomes more obtuse, the strength of the joint increases due
                                    .to an increase in length of the two side welds,-and that'at angles
                                     .of' greater than 130*,'.the skewed connection made with only the two
                                      side welds will be stronger than a three-sided weld connection at
                                      90*. : Based on the above review of the as-built condition, connec-
                                      tions which were welded on either three or four sides were found to
     <
                                      be acceptable.by-SWEC engineering' evaluation.
     '
          '
                                      SWEC review of skewed connections welded only on the toe and. heel
                                      side of the connection; indicated that.these connections would have
                                      to be inspected and evaluated on a individual basis.. This evalua-
                                      tion will also include evaluation of possible insufficient cut back-
                                      on connections made at' angles greater than 135*.
                                      In addition to the undersized welds found on skewed connections, 16
                                    .other undersized welds were observed. These items were identified
          #'
                                      and either repaired or evaluated by engineering for disposition as
                                      noted.in Table IV-4. Of these welds, one type was observed to have
                                      generic. implications. The others were found.to be isolated cases.
     =
                                    : Support SIH-1PSR-581 consisted-of a U-shaped-steel flat bar wrapped
                                    1
                                      around:the pipe. This support was found not to have the required
                         -
                                    : full penetration weld, and several similar supports were observed on
      >
          *                        ;the SIH (High Pressure Safety Injection). system. Investigation
                                    -. indicated that.this= support' design was unique to one design group
                - -        
                                    tand only 21 supports of this type had been detailed. None of these
                                      supports had the required full penetration weld.     N&D's listed in
                                      Table-IV-4 were generated for these nonconformances.
                                    .In addition:to the above supports and restraints, an additional 60
          ,                           supports with approximately 800 welds were visually examined.     No
                                      significant defects were found. See Table IV-5 for details.
 m-
                                                                  IV-4
          -                  .
 $
_
  c.    Conclusions
        With the' exception of those items previously discussed piping
        supports and. restraint welds were found to comply with the appli-
        cable codes and standards. No other problems were identified in
        the area of. inspected welding activities.
  4.    Peactor Internals
  a. . Inspection Scope
        Approximately 140 welds made by the vendor (Westinghouse-Pensacola)
        and at the site by SWEC under Westinghouse supervision.were visually
       . inspected.   These welds represented four joint configurations. The
        site welder qualifications were reviewed. A special mock up test
        assembly used for further welder training and determination of
        actual throat dimensions was reviewed.' The applicable site weld
        procedure specification (WPS) was reviewed as were typical site -
        filler metal issue slips.
  b.    Inspection Findings and Conclusions
        No problems were identified in the area of inspected welding activi--
        ties which were fcund to meet the applicable requirements.
  5.    Reactor Internals Support Stands
  a.    Inspection Scope
       A visual inspection was made of this seismically designed QA CAT 2
        fabrication which was designed to Appendix G of ASME Section VIII.
        It was penetrant tested to Section VIII and the final inspection was
       performed at the vendor's (Portland Engineering) shop. In addition,
        the SWEC M090 equipment specifications for the supports were
        reviewed. Random areas were checked magnetically for presence of
       materials other than austenitic stainless steel and the weld metal
       was checked for the presence of delta ferrite.
  b.    Inspection Findings
       Visual examinations of the welds indicated weld splatter and an
       unusual-appearance of the GTA welds at the edge of shielded metal
       arc (SMA) welded joints. The licensee initiated N&D 11,460 which
       adequately addressed the findings.
  c.   Conclusions
       Except as noted welds met specified acceptance criteria.
  6.   Refueling Cavity Liner Fabrication
  a .'  Inspection Scope
       The refueling cavity liner and spent fuel pool liners were a combi-
       nation of vendor (PX Engineering) supplied panels and SWEC site
                                  IV-5

t.

 o
         . installation.   The shop fabrication was in accardance with SWEC M110
           which called for radiography of some of the butt welds. Site
           installation was to SWEC M952 and called for visual inspection and
           air leak testing of the finished liner.     The NRC CAT visually
           inspected.approximately 100 feet of the refueling cavity liner
          welds, verified the presence of delta ferrite and checked for the
           presence of non-austenitic materials.     The ladder and bolted con-
           nections were also checked for use of non-austenitic materials.
           Review of PX Engineering radiographic film (discussed later) indi-
           cated unacceptable film quality, but noted this was previously
           identified by SWEC vendor inspection on N&D A-006 which was disposi-
           tioned to " accept as is" and voided the. radiographic examination.
          Approximately 30 inspection reports indicating the results of the
          air leak test of the finished fabrication were reviewed.
    b.     Inspection Findings
          The. visual inspection of the welds indicated no rejectable indica-
          tions and the welds contained adequate levels of delta ferrite.
          Review of N&D A-006 indicated a lack of explicit engineering
          explanation on the voiding of RT requirements. The licensee
         -responded to this comment with the issuance of E&DCR T-J-03875 which
          makes the necessary specification changes to M910.
    c.    Conclusions
          Welds met acceptance criteria.
    7.    Electrical Panel Attachment Welds
    a .' Inspection Scope
          The NRC CAT visually inspected approximately 240 panel attachment
          welds for compliance with the specified criteria. The applicable
          WPS document for this fillet welding was reviewed.
    b.    Inspection Findings
The welds exhibited acceptable size, configuration (shape) and met
          minimum drawing requirements for length and spacing.
. c. Conclusions
Welds met acceptance criteria.

I 8. Electrical Support Welds

    a.    Inspection Scope
          Approximately 434 electrical support welds were visually inspected
          for compliance with the specified criteria. The qualification
          records of 9 welders were reviewed. The applicable WPS documents
         were also reviewed.
                                      IV-6

l

 .-
                              _                                                                   _-
                ,
                              1
      J
                   I. b      Inspection findings
                            The;inspecte'd welds met drawing requirements and exhibited accept-
                            able shape and post weld finishing.
                      c.    Conclusions
                       -
                            Welds met: acceptance criteria.
              9. : Instrumentation Supports
                      a.     Inspection-Scope-
                                                ~
                          'Approximately 130 welds, involving supports, tubing blocks', instru--
                          . ment stands, and' standard wall mounting brackets were visually
                             inspected to ascertain. compliance with the specified acceptance
                            criteria. Applicable welding procedures,'. filler metal issue slips,
                            and welder qualification records for 11. welders were reviewed.
    ~               '
          ~
                   - b .-    Inspection Findings
                            The welds inspected met the acceptance criteria. In the process of
                            reviewing welder qualifications-it was noted that welders required
                            to utilize F43_SMAW filler metal were qualified using F42. filler-
                            metal which currently is an unacceptable ASME Section IX practice.
                            However, review of ibis subject with the licensee and SWEC indicated
                            that the. edition of'Section IX in force at the time of qualification
                                      -
                          . permitted this practice.
                           'In the process of reviewing _the filler metal issue slips it was
                            apparent that designations other than that shown in-the WPS docu-
                            ments are used for non-ferrous metals. This lead to an expanded.
                          Lfiller. metal control inspection which-is discussed in paragraph.15
                            of this section.
                                                                                             '
                      c.    Conclusions
                            Welds met acceptanc. criteria.
                  '10.      HVAC Duct and Duct Support Welds
                      a.     Inspection Scope
                            Approximately 133_HVAC duct and duct support welds made by NEVC0
                            were visually inspected for compliance to welding specification and

, -. inspection criteria. Also reviewed were NEVC0 welding procedures-

        '
                            qualified to AWS 09.1 and their structural welding procedure utiliz-
  -
                          zing AWS D1.1 prequalified procedures.     The NEVC0 welder performance
                            qualifications records of five welders were reviewed.as were QC weld
                            records and filler metal issue-slips.
                                                        IV-7
            ~
L
 m
   n+.
                    u
                                                    .L
           '
   ,
                              b .'   Inspection: findings-
                    - '
     <
                                   'Special-efforts were made by.the NRC CAT to verify the required
             '
              .
                                     removal of the galvanizing for all structural AWS D1.1-HVAC support
                                     welds. This.was.a SWEC specification requirement,.but no inspection
                                                                                                     -
                                    . hold point was setup to check for zinc removal. Removal-of zine was
                                     checked in the final QC inspection.

I The NRC CAT noted that the GMAW-S sheet metal ~ welding procedures , ,WP-24, WP-28,.and WP-29, specified ER80S-D2 (formerly ER70S-1B) weld. -

                '
                                     rod. The utilized amperage and voltage ranges for the' filler metal-
                                                                                            -

F size exceeded.the, range for the.short-circuiting mode of metal

                                     transfer. The yield strength.of the utilized filler metal (over
       -
                                     95KSI) greatly exceeded the base metal properties. The licensee

' ~

                                    .. response to the.first. concern was:that the usability of the ER80S-D2
                      _
                                     exceeded that of the_ unalloyed ER705-2 or S-3 and that the high

.e '

                                     strength was not considered detrimental due to the limited. loading
                                     on the, sheet metal welds.    The mode of metal transfer question was
                                   - resolved by discussion with NEVC0 personnel who all indicated that
                                     the parameters actually' utilized were within the short-circuiting
 ,
                                     range. This was confirmed by visual inspection of completed welds.
 J
         ,
                              c.     Conclusions
                                     The inspected welds'were found to conform to the applicableLspecifi-
                                     cations, codes and standards, and the filler metal and mode-of metal
                                     transfer questions were adequately answered.
                             11.     Component Cooler Support Welds
                             la. ; Inspection Scope
                                     Design modifications for the subject ASME Section III, NFS suppart
                                     (CH-CCP-SPIA) requiring plate beam stiffner welding was underway
                                    .which permitted visual observations of.preweld cleaning, layout,
                                                                                                   _
                                     fitup and visual inspection of approximately 100 welds.-in accordance
                                     with. Technique Sheet W2N-1. Review was made of the welding proce-
                                    . dure,. welder qualification records and filler metal issue control.
                              b.-    Inspection results
                                     No. problems were identified -in the area ' inspected.
                  -
                              c.     Conclusions
                                     Welds met acceptance criteria.
                             12.     Fire Protection-Piping System
                              a.     Inspection Scope
                        "
   <                                 Visual inspection was made of._approximately 30 field welds. Six of
                                     which were in a Class 2 piping portion of the system. The inspec-
                                   ition records and surveillance. records for the inspected welds were
                                     also reviewed.
                                                                 IV-8
 (
                         .q-

p p

        b.  -Inspection results
            No problems.were identified in the area inspected.
        c.  Conclusions
            Welds met acceptance criteria.
       13.  Structural Steel Welding
        a.  Inspection Scope
            Approximately 39 beam clip angle welds were visually inspected for
            conformance to drawings, specifications, and codes and standards
            requirements.
        b.  Inspection Findings
            The NRC CAT inspectors found that beam clip angle welds for slotted
            and.non-slotted clips did not meet drawing requirments for fillet
            sizes and number of sides welded, due to a conflict between the
            " typical connection detail" on drawing ES-31J and special detail
            "EH" on this drawing. This resulted in issuance of R0AP 85013 and
            N&D 11973. For additional details see Section V.B.2.
           -Two fillet welds were also found to be undersized. The licensee-
            issued UNSAT IR's S-5A01208 and S-5A01209 to address the undersized
            fillet welds on the-neutron shield surge tank platform and cubicle
            "A" platform, respectively.
        c.  Conclusions
            Except as noted, welds met' acceptance criteria.
       14. Welding Preheat
        a.  Inspection Scope
            In the review of welding specifications and procedures, it was noted
            that a variety of preheating rules were applied for various
            seemingly identical structural type weldments. This finding neces-
            sitated an in depth study of the methods of specifying and control-
            ling preheat.
        b.  Inspection Findings
            Preheat rules are shown in WPS technique sheets (e.g., W200C-W2N,
                               -
 #
            W31.1-01, and W1.1-01) and in SWEC specification M968. These
            rules all relate to structural welding. An attempt was made to
            utilize the complicated rules of 831.1-73 in the W31.1-01 document
            and the AWS D1.1 rules in W1.1-01.    The SWEC rules were found to be
            unnecessarily confusing to all personnel.
                                       IV-9
   4 -

. _ _ ..

    The actual method used in field fabrication was witnessed to be as
    follows: The welders are given copies of the technique sheets with
    their filler metal issue slip and at the same time _are given
    Tempilstiks to be used for preheat and maximum interpass temperature
    checks. .The welding supervisors determine which Tempilstiks to be
    issued. QC does not include preheat as a hold point, but does check
    preheat as a surveillance inspection (IR) item. The surveillance
    inspection reports rarely indicated the temperature observed, but
    rather indicated "S" for satisfactory (meets technique sheet
    requirements). A large number of.IR's were reviewed to verify that
    preheat is one of the criteria checked.
    The B31.1-73 " Rules for Preheat and PWHT", Table 131, permit the
  . preheat for socket, fillet and seal welds to be based on the throat
    thickness of the weld. This approach is reiterated in W31.1-01 and
    W200C-W2N.      Discussions with site personnel (Welding Engineering,
    QA, QC, welding supervisors and welders) indicated that they base
  -preheat on the thickest part welded which is the AWS D1.1 approach
    and the metallurgically sound approach.
 'Part of the confusion in the preheat rules is the inclusion of
    materials which are not used or have extremely limited use, such as
    A572 Grades 55 to 65 and AWS Groups 4 & 5. These materials appeared-
    in W1.1.-01.- In this case there are three sets of rules where only
    one is required. In the case of W200C-W2N there are six sets of
    rules where only one or two are required and again the rules are
    based on throat thickness not base metal thickness.
    In summary the inspection indicated the following:
    1.     All interviewed personnel stated that they are committed to use
           preheat based on the thickness of the thickest part to be
           welded and not on the throat thickness of the weld.
    2.     All interviewed personnel indicated that thicknesses over one
           and one-half inches-required a minimum preheat of 175 F.
    3.     In all cases reviewed, the materials involved were ASME P-1 or
           AWS D1.1 Groups I, II, or III (Except for a specific case of a
           pipe whip restraint pad made of A514, but welded with preheat
           and E7018 filler metal per E&DCR RM-1420S.)
  ' 4.     In all cases reviewed, the sections requiring preheat were
           welded with low hydrogen electrodes (E7018) which are kept in
           portable electrode ovens after issuance for welding.
    5.     The licensee committed to review the various documents specify-
           ing preheat for structural welds, incorporate the M968 preheat
           requirement into the appropriate technique sheet and verify
           that only the preheat (1) column is applicable in W1.1-01.
                                  IV-10
         .       -   - - .  -
                                         .     -   -
                                                           -_      -,     . . . - .
 ;-
    .
       c. Conclusions
          The NRC CAT considered this item resolved on the basis of the above
          commitments and the NRC CAT inspection indicated that 175 F minimum
          preheat is being used for thicknesses over one and one-half inches.
          E&DCR FM-41-804 has been initiated to revise WPS W31.1 to specify
          200 F preheat.
      15. Filler Metal Control
       a. Inspection Scope
          It.was noted by the NRC CAT inspectors that the welding supervision
          was utilizing filler metal issue slip identification that differed
          from that shown on the welding technique sheets. .The scope of fil-
          ler metal control inspections was expanded to include review of
          welding technique sheets, purchase orders,.SWEC ME-xxx purchase
          order specifications, review of CMTR's for filler metal, review of
          the labeling of filler metal in the rod issue rooms, and cursory
          review of approximately 18,000 filler metal issue slips.
       b. Inspection Findings
          The inspection indicated confusion in the use of filler metal
          nomenclature.    The following examples were noted:
                W31.1-72 revised in 1983 specifies RCuNi 'to ME-110 whereas the
                correct identification is ERCuNi'(which appears on the. flag
                tags).
          *
                Technique Sheets called for "Chromenar 521" with no F number
                where the proper identification from ME113 is'SFA5.28
                ER905-B3L.                                                           -
                Some purchase orders specified SFA filler metal to military
                designations.
          *
                The filler metal stock sheets in Receiving QC indicated filler
                metal by SFA and/or military designations.
                Some filler metal issue slips utilized military designations
                rather than SFA designations.
                GTAW filler metal is contained in the Rod Issue stations in
                bins labeled with military designations even though the filler
                metal in the bins is flag tagged with the proper SFA designa-
                tions.
          The confusion in filler metal designations is basically limited to
          non-ferrous materials.     The filler metal CMTR's reviewed met appli-

, cable SWEC'and SFA requirements. The filler metal utilized for

          those items checked met the correct chemistry with the exception of
          one application. The issue slip M365475 called for ERNiCr-3 filler
          metal whereas the technique sheet called for ERNiCrMo-3. An N&D was
                                      IV-11
             _
                                                                       --.       -_.

w

        issued:to address this item. The licensee's response to the. filler
       metal designation question was to point out that the tables-in the
       Appendices of.the nickel alloy filler metal specifications show the
        direct comparison of military and SFA designations. The NRC CAT
       pointed out;that this was not the case for SFA 5.7 for copper
       alloys.

,

  c.   Conclusions
       This item was resolved on.the basis that the correct chemistry fil-
        1er metal (tested to the correct requirements) was utilized for all
       weldments except as noted (which is considered to be an isolated
       case).
 16.   SWEC NDE Activities
  a'.   Inspection Scope
       The NRC CAT reviewed 1663 films representing 90 SWEC field welds.    A
       total of 13 FQC NDE Level II Inspectors were observed and reviewed
        in the process of conducting various examinations (i.e., penetrant
       examinations, magnetic particle examinations, visual weia examin-
       ations, and ultrasonic thickness determinations). The personnel
       qualification records of nine inspectors were examined in detail.
       The system for calibration of NDE equipment was reviewed and veri-
       fied for 14 pieces of equipment. Table IV-6 lists vendor
       radiographs reviewed.
  b.   Inspection Findings
       Review of the film for 90 welds indicated that the radiographic
       review did not identi.y defects in excess of that permitted by the
       applicable standard in three of the welds. Although this represents
       a small percentage of the 1663 films reviewed it represents 3.3%
       based on number of welded joints. In addition to the finding
      .results indicated in Table IV-7, there were several minor report form-
       irregularities such as failure to check off " accept" or " reject",
       incorrect dates on some forms and failure to note conditions affect-
       ing subsequent radiographic interpretations.
       Thirteen FQC NDE Level II personnel which included 2-PT, 2-MT, 3-UT
       and 6-VT inspectors, were observed and evaluated for level of train-
       ing, knowledge of SWEC NDE procedures, and conformance to applicable
       codes and standards rules. The 13 FQC inspectors were judged to be
       fully trained and cognizant in their area of expertise. Review of
       personnel qualification record files of 10 FQC NDE inspectors indi-
       cated conformance to SNT-TC-1A, ANSI, ASME, and SWEC procedure
       requirements.
       Evaluation of the calibration of NDE equipment indicated acceptabil-
       ity in all cases except for the use of one UT thickness gauge.
       U,ltrasonic procedure, QAD-9.52 Revision C dated 9/12/84 para. 5.2.2,
       provided for a one point calibration only. It was discovered during
      -a witness check of ultrasonic thickness on production pipe that an
       error was made during the calibration for the test. The error was.
                                  IV-12

<

                                    ~        ..                              ;-.       -                    .   .                --             -.         .- .
       s
                 , .
                              approximately'7% and that coul'd lead to accepting rejectable condi-
  '
                              tions. The error was detected by the NRC CAT inspector who asked
                              for verification by comparison'with a calibrated micrometer. : S&W
               ,
                              personnel repeated the error and decided to revise the procedure
                              with a.two point check to prevent reoccurrence.- Due to this finding

- 24 test records for work performed to the-one point procedure were ,

                              audited. It.was discovered that the inspectors had actually used
                              three points to verify their calibrations, in addition -SWEC -retested
                                                 ~
 '
                              20 welds and the results of the retest were acceptable.- QAD-9.52 ML
                              Revision A-was issued to require multipoint calibration.
                        'c. -Conclusions
 E                            The three ' radiographically rejectable welds and other minor irregu-

,

                              larities indicated some inconsistancy involving interpretation and

>

                              completion of report forms.-
                       17. -Vendor NDE Activities

[ a. Inspection Scope

.                             The_NRC CAT visually inspected welds representing pressure vessels
                            . supplied by seven vendors as discussed in Section IV.B.2 and shown
                              on Table IV-3.- Radiographs representative of 30 vendor supplied
                              items were reviewed as shown in Table IV-6.
                         b.   Inspection Findings

..

                              The vendor film review resulted in review of approximately 1735 feet -
                              of weld,-21 valves,14 forgings, six clevises, one. support cylinder,
                            - one diffuser, one pump body and one pump gland. . The film reviewed
                              was satisfactory except as noted. One vendor had film that was

, -rejectable on a film quality basis,~ but this was dispositioned to

                              represent unneeded and unrequired radiography in E&DCR FJ10978 and
                            .TJ03875. One film from one other vendor was rejectable because of
          '
film density.

$ 'c. Conclusions ! i_ The review of vendor radiography indicated acceptable technique and L interpretation except as shown in the notes to Table-IV-6. ! t l i,

        '

b

    'l

p I' l

    .
    ..
                                                                                 IV-13

L

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

m

      ju .
^
      g-
    '
                                                                                            ,
                                            ' TABLE IV-1
                                     ' PIPE VISUALLY INSPECTED-           >
        1 PIECE-MARK.    . SYSTEM                    ' PIPE-SIZE (Inches)        MATERIAL
                 '
         CDS-15-5-2-2A'    CHILLED WATER-                 8                 . CARBON STEEL
         CHS-4-3-2-3       CHEMICAL & VOLUME              3                   STAINLESS STEEL
  T
        CHS-44-1-2-2:      CHEMICAL &' VOLUME-            3, 2                STAINLESS STEEL
        CHS-001-719-2      CHEMICAL'& VOLUME'            -1                   STAINLESS STEEL
        CHS-002-198-2-     CHEMI' CAL & VOLUME-           8                   STAINLESS STEEL
        DGS-6-1-1-4        REACTOR GAS DRAIN              4                   STAINLESS STEEL
       .SIL-1-1-3-2-       SAFETY INJECTION.              8-                  STAINLESS STEEL
         RSS-1-3-4-2-      REACTOR C00LANT'               12                  STAINLESS STEEL
        RSS-15-4-4-2       REACTOR COOLANT                12                  STAINLESS STEEL-
        ~MS-34-1-5-2A      MAIN STEAM                     30                  CARBON STaEL-
       'SFC-523-4-3-3-     FUEL P0OL COOLING              10                  STAINLESS STEEL
       .. SI L-1-2-3-2     SAFETY ~ INJECTION             8                   STAINLESS STEEL'.
        FWS-22-6-1-2       FEEDWATER                      16, 20            . CARBON STEEL.
       IFWS-22-4-1-2     'FEEDWATER                       20                 CARBON STEEL
        FWS-22-1-1-2     :FEEDWATER                       20'                CARBON STEEL
       'FWS-22-2-1-2.      FEEDWATER                      20 -               CARBON STEEL
       -FWS-22-3-1-2       FEEDWATER                      20                 CARBON STEEL.
        RSS-18-3-4-21-     REACTOR COOLANT                10                 STAINLESS STEEL
       ~CCE-502-1-2-3      COMPONENT C00 LING             2                  COPPER-NICKEL-
        CHS-002-208-3(2)   CHEMICAL & VOLUME              2                  STAINLESS STEEL
       ?CHS-18-6-2-2      CHEMICAL & VOLUME               4                  STAINLESS STEEL'
                                                -IV-14

'

          ,
 
_
                                                     TABLE IV-2
                             ,
                               < PORTIONS OF PIPING SYSTEMS VISUALLY EXAMINED
                                  .AND FOR WHICH DOCUMENTATION WAS REVIEWED
                  ITEM.             SYSTEM                  PIPE SIZE (Inches)   DESCRIPTION
    .
            - SIH-507-1-1-1         SAFETY. INJECTION           6, 2             STAINLESS. STEEL
        .
            - SIH-507-2-1-li       . SAFETY. INJECTION          6, 3/4           STAINLESS STEEL
            . SIH-504-1-1-2       ' SAFETY INJECTION            4, 3/4           STAINLESS STEEL
            - SIH-7-1-4--           SAFETY-INJECTION            4              -STAINLESS STEEL
            - SIH-7-2-4-2.          SAFETY INJECTION            4                STAINLESS STEEL
             SIH-7-3-4-2            SAFETY INJECTION            4                STAINLESS STEEL
            - SIH-7-4-4-2-          SAFETY INJECTION            4                STAINLESS' STEEL

L - SIH-7-5-4-2 SAFETY INJECTION 4' STAINLESS STEEL

             CI-SIH-507.            SAFETY INJECTION            6,'2, 3/4        STAINLESS STEEL
             CP-408-500             SAFETY INJECTION            2                STAINLESS STEEL-
             CP-407-252-            SAFETY INJECTION            2                STAINLESS STEEL
            - CP-407-027            SAFETY INJECTION            2, 3/4, 1/2    -STAINLESS STEEL
            - CI-SIH-504            SAFETY INJECTION            4, 2, 3/4        STAINLESS' STEEL-
        '

1

             CI-SIH-7               SAFETY. INJECTION           4, 3/4           STAINLESS STEEL
            . MSS-22-2-5-3.         MAIN STEAM                 -30               CARBON STEEL
                    ~
             M'SS-22-1-5-3:      -MAIN STEAM                    30             . CARBON' STEEL-
             MSS-35-1-5-2A          MAIN STEAM                  30-              CARBON STEEL
             MSS-35-2-5-2           MAIN STEAM                  30               CARBON STEEL
                                                          '
             MSS-35-1-5-2B          MAIN STEAM                  30             -CARBON STEEL
            - MSS-503-1-1-2         MAIN STEAM-                 30               CARBON STEEL
      1
            -MSS-503-2-1-2          MAIN STEAM                  30               CARBON STEEL

! MSS-503-3-1-2A MAIN STEAM 30- CARBON STEEL

L

  -

b IV-15 C_

y,. . . ._ . -. . -. - - . . . - - -. -. . .- . - p '

                                                                                                                                                                              ,
     -
                                                                               TABLE IV-3                                                                                       :
                                               TANKS,' PRESSURE VESSELS AND HEAT EXCHANGERS
                                         VISUALLY INSPECTED AGAINST DRAWING REQUIREMENTS
               DESCRIPTION OF ITEM INSPECTED                                                 MANUFACTURER                                             FINDINGS
              -(CHS-TK2)' VOLUME CONTROL _ TANK                                             LAMC0 INDIKTRIES, INC.                                Acceptable
               (CHS-E7) LETDOWN REHEAT-HEAT EXCHANGER                                      ATLAS INDUSTRIAL MANUFACTURING                                 (1)
             _(CCP-TK1)'. COMPONENT COOLING SURGE TANK
                                             -
                                                                                           P.X. ENGINEERING CO. INC.                                      (2)

E

                                                                                           P.X. ENGINEERING.CO. INC.                                      (3)

-

               (CCE-TK1). CHARGING PUMP COOLING' SURGE

.

                           TANK                                                                                                                                                  .
                                                                                                                                                                                '

.

             '(EGF-TK-2A) GENERATOR FUEL OIL DAY TANK                                      P.X. ENGINEERING CO. INC.                                      (4)                    ,

'

'      '
               (3CHS-E2). VERTICAL LETDOWN HEAT                                            JOSEPH OAT C0. INC.                                            (5)
                           EXCHANGER
                                                                                                                                                                              '
             -(CCI-TK1)~ COMPONENT COOLING SURGE TANK                                      P.X. ENGINEERING C0. INC.                                      (6)
            '(SIL-TK10) ACCUMULATOR TANK                                                   SOUTHWEST FAB. AND WELDING CO.                              _(7) _

'

            -(3SFC-E1A) FUEL POOL COOLING HEAT                                            AMETEK, INC.                                                    (8)
                            EXCHANGER
               (RSS-ElB) RECIRCULATING COOLER ~ HEAT'                                     JOSEPH OAT CO. INC.                                             (9)
                           EXCHANGER.

'

            L(RHS-E18)' RESIDUAL-HEAT REMOVAL HEAT                                        JOSEPH OAT'CO.-INC.-                                        (10)
                           EXCHANGER
            =(CHS-TK5A)(11) BORIC ACID TANK.                                               RECO INDUSTRIES, INC.                                      (11)
                                                                                     NOTES
                                                                                                                                                                                .
               (1).-Fillet welds on supports undersized. (N&D 11641-Accept-as-is)
               (2) Undersized fillet welds on all nozzles, manways and supports. (N&D 11910),
               (3)' Undersized fillet welds on'manway, one. coupling and'some supports. (N&D 11912)
               (4) Undersized fillet welds on 7 nozzles and portions of supports. (N&D 11914)
              (5) Undersized, fillet welds.on 4 nozzles and on supports. (N&D 11915)'                                                                                            '
                                                                                                                                                              ~
                                                            -
                                                 ~

.

            '(6) Undersized fillet welds on manway, 5 nozzles and anchor pads. (N&D 11911)

'

              (7) Undersized fillet welds on anchor ring. (N&D 11994)
            -(8)'fundersized fillet welds 1on supports, overground base metal at one nozzle.
                     .(N&D 11913).

~'

   .
           :(9) Undersized fillet welds on 3 nozzles, 2 saddles, support brackets and
                      unacceptable weld surface condition on one reinforcing pad. (N&D 11918)

7 -(10) Undersized. fillet welds on one nozzle reinforcing pad weld and one support-

.
                      bracket.-(N&D.11919)
'
              (11) Undersized fillet welds on anchor pads. (N&D 12167)
p-
                                                                                     IV-16

.

                                  --w,. w--s       --  s   +,.y.-,-- . , , ,-c e yv-  *-cer,      -+--,wm1---, ,-   -rm -. - - - . - , - . ,      -%.       if-%.      -y-. ,
                                                     - - . .                      ._              -            . - . . ..                         -   ..            . . -      .
   m
            .
                                                                           ~ TABLE IV-4
 ,
                                           ' SUPPORTS EXAMINED IN DETAIL AGAINST DRAWINGS
    >
                     : SUPPORT'                                 FINDINGS-                                    SUPPORT-                               FINDINGS-
                       MSS-1PSR-122                                      (1)                                 SIL 1PSR-028                                  (2)
                       RHS-1PSR-014:                                                                         BDG-1PSR-030,
                     'CHS-2-PSSP-420                                                                         CDS-2PSR-001
                       CDS-2P'SA-003'                                    (3)                                CCP-2PSR-062
                                                                                                                                                                                  .
   ~.
                       RHS-IPSSP-405-                                   '(4)                                SWP-2PSSP-409/410-                         '(5).
                                                                                                                                                        -
                       CHS-2 PSST-282                                    (7)                                CHS-2PSSP-426/427                              (6)
              ^
                  - SFC-3PSR-147                                                                            SFC-3PSR-126
                    ' FWS-4PSR-003                                                                         ~ FWS-4PSR-053
                    - FWS-4PSR-050                                       (8)                              - MSS-3PSR-11
                  :
                       MSS-4PSR-019                                      (9)                                 FWA-4PSR-245                                                             ,
                  :' RSS-4 PSST-140                                                                         SWP-4PSSH-119                             (10)
                                                                                                                                                                                    -
                  . RSS-4 PSST-031-                                                                         RSS-4 PSST-134
                       SVV-4PSSP-034                                   (11)                                  FWS-4PSR-051-
                  '
          -
                       FWS-4PSR-001                                                                         FWS-4PSR-018-                             (12)
                       CP-379008-H006                                                                       CP-379008-H005
                       CP-407018-H002                                  (13)                                 RCS-1PSSR-1093
      -
                    :  SIR'-IPSR-581                                 -(14)                                . BRS-2PSSH-006
                  - QSS-4 PSST-115
                -                                                                                                                                                                     ,

i , F- ! i r.

 -
                                                                                     IV-17

,

                                                                                                                                                                               6
                     ,    .i%4     ....,-.--e   ,  ,        ,.-.,-,y-,     , . - . ,       .,,-ir   , _ -  ,v.   ,,.-.-.~4,, - 4,,m.. , ,m. - ~ ,       , - - , _ .w-,-*-. , , -.

m ,

                                  TABLE IV-4 (Continued)
                       SUPPORTS' EXAMINED IN DETAIL AGAINST DRAWINGS
                                    1       NOTES
 '(1) Seven obtuse skewed fillet weld's undersized.       (N&D 11527)
   (2) Two fillet welds more than 1/16" undersized.       (IR#P5A91086)
   (3) Two skewed fillet welds undersized.     (N&D 11527)
 -(4)'Oneskewedfilletweldundersized.          (N&D 11527)
   (5)--Two skewed fillet welds undersized.    (N&D 11527)
   (6) Three 6 inch long welds short by 1/2 inch.      (IR# PSA91101-repaired)
   (7) One fillet weld undersized.    (IR# PSA91101-repaired)
  -(8) Eight inch long flare bevel weld short by 1/4 inch and weld not filled to
         flush. (IR# PSA91144 and IR#PSA91115-repaired)
   (9) Two welds rotated 90 from location on drawing, one skewed fillet weld
        undersized.- (N&D 11527)
 -(10) Three skewed fillet welds undersized.      (N&D11527)
   (11) Skewed fillet weld undersized.   (N&D 12178)
   (12) Extra plate-cn support, 8 seal welds where drawing requires fillet welds.
         (N&D11543)
   (13) 0ne skewed fillet weld undersized.    (N&D 11543)
   (14) Full penetration welds required. Partial penetration obtained.      (N&D 11652
         and 11653-Generic problem with 21 brackets)

i ,

                                            IV-18

E

               _ _
                                                                               , , ~ .     ,                       ..-._an    -sw    ,.                 . ..a   a _,     wa   .s.
                               *
                                     1
   ,                                             .
                                                                                                                                                                                  .,
                                                                                                                                                                     .
                 .
                                   _
                                                                                          TABLE ~IV-5
                                                                   SUPPORTS WHICH WERE' VISUALLY EXAMINED
                                                                                                                                                                                   '
                                                                                                 ,
                                                                                       '
                                         : SFC-3RSS-123-                                 MSS-4PSSP-401-                         - MSS-4PSSP-400
                                                                                                      '
                                          -CCF-1PSR-016                                  CCP-2PSR-100                           - CCP-2PSSP-405
             '
                                            CCP-2PSR-003L                                SIH-2PSSP-012                         - CCP-3PSR-008-
               -                 ~
                                            RSS-4PSSH-141-2-         -
                                                                                         SIL-3PSR-051                             MSS-4PSSH-128
                                         - CCP-2PSA-010-                                 CCP-2PSR-009                             CCP-2 PSST-024
                                         . CCP-2PSA-010                                  CCP-2PSR-076                             CCP-2PSR-070
                             .
                                                                                                                           -                                                       .
                                       - CCP-2 PSST-077-                                 CCP-2PSR-071                             CCP-2PSA-019
                                                                                               ~
                                           CHS-3PSR-090                                  CHS-3PSA-037                             CHS-2PSR-091
                                          -SFC-2PSA-026                                  CDS-2PSR-004~                            CVS-2PSR-091
                                       ,
                                         ' CP-355700-H004                                CP-355700-H007
          .
       9
     .

4

                                                                                                                                                                                   i

A.

          '
         '.

i i

                                          a
k'

i >

                           _
                                                                                                 IV-19-

i- .

                   .1. ' ?
         , ,                           ,      .    . , - . . . > .   ....,J,..,---..,e       .,-~--..........__,,,_v._~--.,.,
                                                                                                          ^
                                                                                                                                           ,.-,_..,,m,,       -, , ,. - . , ' . -
                                                                                                                                                                                -
 ,.      , . .       -          . . _ _ . . _ - _ _ _ _ _ _ - _ _ _ - _ _ - _ - _ - _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - _ _ _ _ - - _ _ _ _ _ - - _ _ _ _ _ _ - _ - _ _ _ _ _
                                                                                                                                                                                                             TABLE IV-6    -
                                                                                                                                                          VENDOR RADIOGRAPHS REVIEWED
                                                                                                                                                                                    .Clevices
            '
                                                                                                      . .
                       ..                   ..
                                                                                                             Pumps                                                                        Forgings                            l Feet
            -. Contractor' ' Welds                                                                               Valves- ' Castings                                                                                               of Weld                        Film  Results-    Notes
                                                                                                                             '
              ! Permutit .                               -6                                                 --                                                                                          --
                                                                                                                                                                                                                                   11                          52      A
             :Ametek Div.                                     6                                             --                                                                                          --                        --
                                                                                                                                                                                                                                                             -40       A
                 Schutte &
               -Koerting
               .
              ~ Bingham ..                                    5                                             --                                                                                          --                        --
                                                                                                                                                                                                                                                            108        A
             .' Williamette'                                                                                                                                                                                                                                                                      .
             = REC 01                                         6                                             --                                                                                          --                        --
                                                                                                                                                                                                                                                               39      A
         ,
              'Walworth                                                                                     3 valves-
                                                                                                                                                                                                             '
                                                             --                                                                                                                                         --                      :--                         142        A
                 Graver.                              --                                                    --                                                                                          --
                                                                                                                                                                                                                             1089                         .206-        A
                ' Joseph Oat-                                7                                              --                                                                                          --
                                                                                                                                                                                                                                  20-                          40      --
                                                                                                                                                                                                                                                                                   (1)            4
   ' -
                'PX Engrg.                           12-                                                                                                                                                --
                                                                                                                                                                                                                               134                             75      --
                                                                                                                                                                                                                                                                                   (2)-
                 IIT/Grinnel                            ---                                                 2                                                                                           --                        --
                                                                                                                                                                                                                                                               38      A
                 Wisconsin. -                                --                                            --
                                                                                                                                                                                                           1                      --
                                                                                                                                                                                                                                                               36      A
             : Centrifugal                                                                                                                                                                                                                                                                        ,
             -Dresser'                                       5                                         ~--                                                                                              --                        --
                                                                                                                                                                                                                                                               19      A
              ~ Industries
                 Gould' Pumps                                                                              1 body                                                                                       1 gland                   --
                                                                                                                                                                                                                                                            -43        A
             : Anchor                                        --
                                                                                                           2 valves                                                                                     --                        --
                                                                                                                                                                                                                                                            110        A
             : Darling        ,

,

   ,
             LTubeco                                         17                                            --                                                                                           --                        --
                                                                                                                                                                                                                                                            180        A                          t

.

                 Southwest-                                  60                                            --                                                                                           ---
                                                                                                                                                                                                                 .
                                                                                                                                                                                                                 '
                                                                                                                                                                                                                                  --
                                                                                                                                                                                                                                                           750         --
                                                                                                                                                                                                                                                                                   (3)
                 Welding
                 YUBA Heat-                                 --                                             --                                                                                           --
                                                                                                                                                                                                                               100                         100        ~A
                 Transfer
             'LAMCO
              -
                                                             --                                            --
                                                                                                                                                                                                           6~                     --
                                                                                                                                                                                                                                                           118         A
             ; Rotterdam                                     --                                            --~                                                                                          --
                                                                                                                                                                                                                                 80-                        .60        A
                 Gary Tool:                                 --                                          '--                                                                                             14                        --
                                                                                                                                                                                                                                                               28      A
 ' '
                 Texas Pipe                             '--                                                --                                                                                           --
                                                                                                                                                                                                                                  15                           13      A

,- -

                                                                                                                                                                                                                    IV-20
             .                                                                       _ . . _ . . _ . . , ._.-                                                                                                  . . . - - . . . , _ . . . . . . _ . _ _ _ _ _ _                  __       -_ ,__ _

'

                               ,         .~ -        .           .           ~ .                    . . _ -       --.- . _ - . - . . - . -                                       .-                                 - _                        . . . - .
              ,
                            /C} _
                                               -
                                                                             .
                                                                                                              ~
        [                                                                               TABLE.IV-6 (Continued)
                                                                            ; VENDOR RADIOGRAPHS' REVIEWED
      .
                                                                                                                                                                                                                                                         '
                                                           ,
                                                 <
                                                                                             -CleUicesi
                                                     '
                                                                      Pumps                  : Forgings . Feet                           .
                 -Contractor                     Welds              ' Valves
                                                                    .                          - Castings of Weld                                 Film         Results                                                  Notes.
                 -Pro Fabi                              --            ---                        --                    100                      93                --
                                                                                                                                                                                                                         (4)
                   Rockwell                             15            --                         --                     --
                                                                                                                                             . 143                --
                                                                                                                                                                                                                         (5)-
                 1 Westinghouse!                        --            1 valve                    --                     --                      48             'A
                  -(Cheswick)_
    s              Haywood1 Tyler                       --            Diffuser                   --                     --
                                                                                                                                                  9              A
                 ' Pacific V'alves -                  -
                                                                   -2 valves                     - - - -                --
                                                                                                                                                14               A
                   Henry Pra'tt                                                                                                                 40
                                                               -
                                                      - --
                                                                      24"_ Disc                  --                     ---                                      A
                   Sulzer                               1-           MSIV                        --
                                                                                                                        15                     '12               A
                   Reco-Koch-                           8             ---                        --                        6                     4               A                                                                                       i
                    Fisher-                             ---
                                                                   -1 valve                      --                     --
                                                                                                                                                25               A
                          ' Controls                                                                                                                                                                                                                     '
                             /
          .
                   Leslie Co.                           --
                                                                      1 valve                    --                     --
                                                                                                                                               100               A
                ' Carrier                            - --             --                         --                     --                     ---                --
                                                                                                                                                                                                                         (6)
 t-
                                                                                                            NOTES
                  . -                                                              .
                   A : . Acceptable - meets Codes and Standards requirement
                 '. (1) . . View 2 of. nozzle "A" on; the Letdown Heat Exchanger showed a _ linear
                                      indication 1/2 to-3/4 inch long which was not recorded on the reader. sheet.
                              ~
                                    _
                  ~(2) - Reader sheets for acid tank and caustic tank were in the wrong film
                                      packets; unsatisfactory radiographs on the pool liner and the storage liner -
                                   'were-determined by engineering to be unnecessary and were deleted from the
                                  Lspecification by._ E&DCR number F-J-10978 and number T-J-03875.
                                                                                                                                                                                                                                                         ;
                                  '
                    (3) - Several Eradiographs displayed indications requiring re-radiographing or

,o visual examination to confinnEacceptability, i.e. , weld '3, SW-4 - an indi-

                                      cation with_ a cracklike appearance was re-radiographed at various angles -
                                      and found to be a surface condition.
                    (4) -HMany film above 4.0 density causing interpretation difficulties even with
-high intensity viewing. .N8D 11,953 was issued to correct.this condition. j
                      _

. 7

                                                                                                            IV-21
                                             -
                                                                                                                                                                                                                                                         4
            ,           ,           4.- - ,,       m- , ,_. ,.                    n,%,,....e                    -
                                                                                                              ..,_,_w.        .,_,,-._m._,--           . ~ , - - - , - - - . . _ , . _ - . . , _ _ _ . - . , . ~ , _ . . . - . . - . _ - . - . .
                                               '
                                          TABLE'IV-6.(Continued)
                                       -VENDOR RADIOGRAPHS REVIEWED
      .
        '(5)   . Indication noted on one film: Re-radiography using special technique-
               ' determined that' the indication is an ID surface condition.       Acceptable.
        .(6)- Film not available for review. ' Paper work found to be acceptable.
                                             ,

, i: ,

 :

f i J

    ,                                               IV-22

b

     ;_-.-           --
                                  q                                        7 -
                                                                             t
                                        4,
                                                  '-
                           i     1
                                         '
                . ,e    *2                                                                    ,
                                                     
                a            .C
                             [t                           TABLE'IV-7 h
                             ' '
                         i            SWECRADIOGRAPHICFILMREVIEWRESULTS
                                                                                       --
 A. Of the 93 field fabricated welds reviewed'the following radiographic con-
    cerns were noted:                                                                ,
                                                                                            '
    1.       Weld 3-HVU-042-3-2 CI HV0-1, FW-1: aligned porosity view 56-70.                    I . R.
              P5A01490 was: issued for repair welding.
    2.       WeldCI-RCS-513,$FW1:' rejected .for lingar indication-in excess of code
              in one area. N&D11,f43was'it, sued; repair.                                 p
    3.       Weld CI'RSS-501, FW-66; rejected for , linear indications indhree areas -
             0-10, 20-30 and 30-0. N&D 11,470 was'. issued; repair.
    4.       One weld, 3115-00I5'2-2.'CP-407009, FW-1; was withheld for further review
             by CAT inspector oue to incorrect view being re-radiogrnphed. The
            - original viev 3-4 was rejscted by SWEC for film quality. The re-radio-
             graphed area in the packagt was 2-3 rather than 3-4. SWEC
             re-radiographed the area and completed the package with 100% coverage
             and the correct view.
    5.       Welds CP-374-019, FW15 and (GE 843E740) fiSS-5843 Line #1, FW2:
             Pentrameter in weld' area r:reventing adcquate interpretation.
                                                        .
             Acceptable on fe-radiogrg hy.
    6.       Weld CJ-RSS-9, FW4:                Film artifacts-<in both films in the same area.
             Re-review of film verified originaU dis' position as acceptable.
                                                                 ,
                                              t
                                                                   \
                                                              ,
                                    I
                                                            IV-23
                                  .

- .-y _..m.. ~ ,- - ,p--,

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

.

        c
                                                                                                                                '
            (V.   'CIVIlfAND STRUCTURAL CONSTRUCTION
                   A. _ Objective

. 1The objective of _ the appraisal of civil and structural construction was.

                          to determine by evaluation of completed work and by review of documen-
    "
<
                          tation_whether work, inspection, and test-activities relative to civil
,
                          andjstructural construction areas ~were accomplished in accordance with
                        : regulatory. requirements, Safety Analysis Report (SAR) commitments,
                        cand project specifications, drawings and procedures.

I- B. Discussion

                         The specific' areas of civil and st'ructural construction evaluated
                        .were: . concrete, reinforcing steel configuration, cadwelds, structural'
                         ~ steel installation and bolting, masonry walls, the concrete expansion
                ,
                         anchor bolt. qualification program and building settlement.
                        <For concrete', reinforcing steel configuration, structural steel
                        ' installation and bolting, and masonry walls, a physical or hardware
                          inspection of previously inspected and accepted work and a Quality.
                       : Control (QC) documentation ~and field procedures review were conducted.
      o-                 A review of QC documentation and field procedures was performed for
                         cadwelds,_the concrete expansion anchor bolt qualification program and
                         building settlement.

,

                         1. ' Concrete Activities

- 3

                         a.        Inspection Scope

i- -The: reinforced concrete activities reviewed by the NRC. Construction

                                  Appraisal Team (CAT) inspectors included two construction openings,
                               -two. removable hatches and one area in which the concrete was removed
                                  for' repair. These areas were' reviewed for'conformance of rebar                                  i

.

                                  placement with the design drawings (see Table V-1), specifications                                '
                                  and: associated design changes.

L f .Three concrete placements were reviewed and general concrete.

                                  quality was'also examined from surrounding areas for conformance to                               ;

i. site specification requirements. Records associated with the [ concrete placements were also reviewed. This review included the

  -
                                 -concrete placement reports, concrete placement checklists and the

,

                                  field inspection reports for reinforcing steel.                                                   '

i. Concrete-placements for Containment Building removable s1 abs RS-F n and RS-B and dome ~ vent pour back were observed by the NRC CAT !

                                : inspectors. The-in process concrete tests were compared with the

. . limits shown in SWEC Specificiation 281, Revision 1 " Mixing and.

                                 . Delivering Concrete" for slump, air, temperature, unit weight,
          '
                                  truck revolutions and water / cement ratio.

(' The cadweld splice performance records were reviewed to determine

                              -adequacy of.the production and sister splices testing frequency.
                               .

r Documentation and requirements for cadwelder qualification and j requalification procedures were reviewed. The qualifications of-

             .                                                           V-1

f i

                             . - . . . . _   . . _ - - - . - - - - . .       . .  , , , - . . - - - , . . , . - _ - , , . , , -   -
 g>                    .
          m             ,
                          <
      <         ;Q
                                Lthree:cadwelderswerecheckedtoseeif'theymetvisualandtensile
      ,
          ,
                 -
                                   test--requirements.
                            b.     Inspection Findings
                                 -Inlthe,five concrete areas inspected.one. area was identified where
                                :the rebar was not placed in'accordance.with the design drawings.
                                   In this area (cubical D of the Containment. Building), the NRC CAT
                                   inspectors reviewed a void in-the grout placement for wall attach-
                                : men _t plate 3RCS-PRRG. SWEC Field Quality' Control (FQC) had issued
                                1Nonconformance Disposition (N&D) Report 11,544 on September 25,
                                  1984 to' document the grouting deficiency. It was noted by the NRC
                                -CAT. inspectors'that several vertical #11 rebar were visible in the
                                  area and wereJin' a bundled conditiori.  The design drawings (EC-51P
                                  Rev. 4 and EC-51G Rev. 5) did not call for vertical bundled bars-in
              ~
                                  this' area. The N&D was revised to include the bundled #11 rebar..
                                  The'N&D was dispositioned."use as is" and the supporting calculation
                               .12179-SE0-C51.3 Rev.:0 was reviewed-and found acceptable.
        T
                                -The 16 cubic yards of concrete placed were observed to be in accord-
                "
                                !ance with Specification 281, Revision 1. The in process concrete
                               " test results for the Containment Building dome cap concrete place-
                               > ment were compared with the specification and found to be accept-
 E                                able. SWEC.FQC rejected-3 cubic yards of concrete when after
                                  initial samples were obtained additional water was added to the
                                  truck mixer making the water / cement ratio indeterminate. . Based on
                                  FQC actions and the'in process test results, no' discrepancies:were
                                  noted.
                   #             Concrete truck' mixer uniformity tests for. truck number 77 at the
                                 Soneco Service Batch plant in Groton, Connecticut was observed by
                                  the NRC CAT-inspectors. The Standard Specification _for Ready-Mixed
                                 Concrete-(ASTM-C-94) was used as the basis for conducting truck        ',
                                 mixer. uniformity tests. Appendix XI entitled " Concrete Uniformity
                                 Requirements" provide. the acceptance. criteria for determining truck-
                                 mixed concrete' uniformity.
                                 The test variations'at approximately 15% and 85% of the load were
                               . compared for air content, slump,. concrete unit weight, mortar unit
 ,
                                .weight, weight of aggregate and compressive strength. The NRC' CAT-
                                  inspectors: observed the slump, air content and unit weight test
                                 associated with the truck uniformity tests. The' tests observed

i were found to be in accordance with the specified test requirements <

                                 and the test equipment,.when required, was-in calibration.
   '
                                 During the inspection of general plant structures, it was noted
                                 by the NRC CAT' inspectors that the rattle space between the Reactor
                                 Containment Building and the Main Steam Valve Building (MSVB) was
                                 less than.that specified in the.FSAR Section 3.8.5.1. The FSAR
                                 required a'four inch space between these two buildings. The

, . existing' space was found.to.be approximately three inches. The

            -
                                 licensee' stated that the FSAR will be revised to show a minimum
                                          ~

-

                                 space of two: inches between these buildings. The NRC CAT also noted

1

                                 that-debris and concrete were present in the rattle space between
                                 the' Reactor Containment Building and the Main Steam Valve Building.
                                                               V-2
     ,               A                  ,
                                                     ,
  The debris was subsequently removed. An evaluation was to be
  perfonned by SWEC Engineering in order to determine whether the
  concrete could be left in place.
  No problems were identified with the qualification of the three
  cadwelders that were reviewed.

c. Conclusions

  The concrete quality was found to be acceptable and rebar was
  placed in accordance with the design drawings for those areas
  inspected. The concrete material certification and testing records
  reviewed indicated conformance to the construction specifications
  and regulatory connitments. Concrete chipping and rebar cutting
  inspected was performed in a controlled manner.
  The failure to identify a rattle space smaller than committed to in
  the FSAR and concrete in the rattle space between the Containment
  Building and the Main Steam Valve Building is indicative of inade-
  quate inspection in these areas. This condition should be evaluated
  and additional inspections performed if interferences in the rattle
  spaces are found to be unacceptable.

2. Structural Steel Installation a. Inspection Scope

  Installed and QC accepted structural steel was inspected for member
  size, configuration, and conformance of bolted connections to the
  design drawings (see Table V-2), specifications, and associated
  design changes.
  Structural steel bolts were tested using a calibrated torque wrench
  to determine whether the bolts had been properly tightened. The
  inspection sample was selected randomly from structural steel
  installed in the Reactor Containment Building, Main Steam Valve
  Building and the Control Building.
  Structural steel installations inspected included 34 members and 36
  connections for proper sizes, dimensions and configuration, and 297
  high strength-bolts for torque. The licensee inspected an
  additional 692 high strength bolts for torque during the NRC CAT
  inspection.
  The bolts tested included seven-eighths inch and one inch diameter
  A325 bolts. The site used load indicating washers (LIWs) in the
  structural steel connections. These were inspected on the basis
  of measurement of the gap adjacent to the LIW. Test torques were
  obtained by the NRC CAT inspectors using a Skidmore-Wilhelm tension
  tester in which bolt tension and torque values were measured.

b. Inspection Findings

  No discrepancies were identified between the 34 installed
  structural steel members inspected and the design drawings.
                               V-3
            ,
                ,  . .. _ ., ..                         .        _ . _ .. .        _ - . _ . . ..                   _.      _. ___
 '
                                                                                                                                      ,
       n'               L

a v ,

                                              .Nine structural' steel connections in the Main Steam Valve Building
                                               were found with' incorrect bolting and welding configuration. 0f                       '
                                                the nine,'five slotted structural steel connections were found not~
                                             .to meet the installation requirements. -Four of the slotted connec-
              ,                                tions were found with bolt torques in excess ~of 450 ft-lbs, while~
                                                the design detail required the bolts to be finger tight. The fifth

. . - = slotted bolt connection was found without any hardened washers as

                                               required by AISC.
                                        ' Four other structural connections.did not comply with the clip
                                              ' angle to embed weld detail as'shown on drawing ES-31J, Revision 3.
   -

4

This detail required a seven-sixteenths inch fillet weld on all.
                                             .three sides of the clip angle, but in the actual installation only

I

                                               one side of the clip angle had been welded. ' Additionally, the

b

                                               detail'on ES-31J, Revision 3 requires a seven-sixteenths inch weld
                                               but the actual field weld was five-sixteenths ~ inch. Based on these

'

                                               concerns, SWEC FQC reinspected all structural connections in-the                       ,
                                               MSVB.   Inspection Report (IR) 55A01205 was issued which describes 70
                                             ? slotted connections that were not finger tight, had peened threads

[ and were missing-plate washers. N&D 11,973 identified 96 fixed end E connections that did not meet the welding requirements for Typical ! ;End Connection detail on ES-31J Rev. 3. Based on the connection

                                              ' problems, SWEC issued a Report of a Problem-(ROAP) on March 22, 1985-
                                               to determin~e the generic and reportability implications of these

, connections.

                                               In discussions with licensee personnel regarding the use of L'IWs',
-it was.noted by'the NRC CAT inspectors that SWEC Engineering did

2

                                             -not perform any on-site testing to independently verify the

> - performance of the LIWs. SWEC relied on a report on LIWs by_the:

                                             .AISC Research Council on Riveted and Bolted Structural Joints.as the                 '
                                               basis for acceptance and use of LIWs. 'As additional verification,
                                             -the SWEC specification for structural steel. required the supplier to
                                               test'3 LIWs from-each lot. Several examples of. these tests perfor-
                                                                                                  -

s "

                                              med by Thames Valley. Steel Corporation'-(TVS) were provided to the-
                                              NRC CAT inspectors.           From the TVS test report-it was not clear how
  =
                                              TVS conducted the test. In addition, SWEC. Engineering was unable to

j provide specific information as to how TVS conducts the LIW accept-

-
                                              ance test. Also, there was no information available in the manufac-

'~

                                               turer's test data to correlate bolt tension to the 0.005 inch LIW
                                          _ gap acceptance criteria.
                                              Based on.SWEC Engineering's response to the NRC CAT inspector's
questions regarding the use and acceptability of LIWs, it was

E apparent that'SWEC Engineering did not adequately investigate the !

                                              parameters important and essential to the LIW's performance.
   -

l To determine bolt torque-tension relationship and verify performance .. of the'LIWs, 21 tests using the Skidmore-Wilhelm tension tester were [ performed:on-site at the request of the NRC CAT inspectors. A total I  :

                                              of eight of the 21 LIWs tested did not meet the minimum bolt tension

P .as-required by Table 1.23.5.in AISC specifications for the Design,

_ Fabrication and Erection of Structural Steel for Buildings.

f p  : Bolts were found in testing to be as low as 34.5 kips in tension

                                                                                V-4

L

     ,,           2_        _ _ . _ . __ _ _.-_-._._.                                                   _ _ . _ _ _ . _ _ _          -
   _ _
                                                        ,
                                   .
                                                ,
                                                      versus the minimum requirement of 39 kips and had met the LIW
                                                      gap acceptance criteria. The'eight failed LIWs consisted of'six
                                                     manufactured by_ Cooper-Turner and two by Bethlehem Steel. -The'LIW
                                                   : gaps appear to give an apparent accepttble result but actually the
                                                     bolt did not meet the minimum required tension. SWEC issued a
                  1
                                                      Report of a' Problem (ROAP) regarding the Cooper-Turner washers. The
       '_
                                                  _NRC' CAT inspectors did not agree that the scope of LIW performance
                                                     concerns was limited to only Cooper-Turner washers based on the
                                                   : limited testing and test results for LIWs conducted on site.
                                                   :In the Main Steam Valve Buildingr the' Containment Building, the ESF
                                                     Building and the Auxiliary Building, structural steel connections
                                                     containing seven-eighths: inch and one inch A-325 high strength-bolts
                                                    were-torque tested to 425 ft-lbs and:700 ft-1bs respectively.
                                                    Approximately 256 seven-eighths _ inch diameter A-325 bolts were
                                                  . torque tested to 425 ft-lbs with only four bolts not achieving the
                                                  7 minimum torque. Approximately 41 one inch diameter A-325 bolts were
                                                     torque tested to 700 ft-lbs with all bolts achieving the minimum.
                                                  ' torque. As'a result'of the concern with the performance of the LIWs
                               ,
                                                    the licensee tested an additional. sample of 692 seven-eighths' inch
                                                    diameter A-325_ bolts with_only six failing to meet minimum torque.
                      '
                                          c.        Conclusions
                                                    In general, the structural steel installation activities for member
                                                  . size and configuration'were found to be in conformance with the
                                                    design drawings!and specifications. However, deficiencies were
                                                    identified in the following areas:
                                                    A significant number of' discrepancies were identified by the NRC
                                                    CAT inspectors in structural steel connections in the Main Steam

c Valve Building. Based on the NRC CAT inspectors. finding, the P '

                                                    licensee inspected all the connections in the Main Steam Valve-
                                                    Building. The deficiencies were identified on-inspection reports on

'

                                                    the 70 slotted connections and an N&D was~ issued on the.96 welded
                                                    connections. The_ROAP issued March 22, 1985 by SWEC was to initiate
                                                    action to determine genenic and reportability aspects.of structural
                                                    connections at the site.
                                                  cA' total of 989 bolts were torque, tested by the NRC CAT'and the
                                                    licensee with only 10 failing to achieve the minimum. inspection
                                                    torques. The high strengths bolts installed in the Class I struc-

i tures appeared to be properly installed. b . 3. -Masonry Walls i L a. -Inspection Scope l~ In the area of masonry wall construction, the NRC CAT inspectors

reviewed specifications and completed block walls. For the block
                                                   walls,' the inspection' concentrated on the bracing modifications.
                                                                   -
                                                   All masonry wark reviewed was in the Control Building (See Table
                                                   V-3).
                                                                                        V-5
                                                                                                                             .
  W1      F t-   ,e yv- g -reees--   pW 9   y8,-V    7 '-*F*'tw-'1    - * 'e---4pr+wv-@                                    "
                     v-
         ,
           / '
   .- '
                                       E     >
  <
      -          '-
                        'b. . Inspection Findings
                                 The masonry (walb seismic bracing modification installations were
                               (compared to the design drawings and .in' general, found to conform
  '
                                .with design drawings and specifications. -The structural steel
    ~
                               itrusses used.to brace ~the concrete block walls were reviewed as part
                                 ofithe structural ~ steel sample.
                                 Duringithe NRC CAT inspection it.wasidetermined that walls were not
                                 constructed as' safety-related structures. However, the. bracing was-
                                 constructed as Seismic. Category ILstructures.
           '
    ,
                         c.      Conclusions                 ,
           ,
                                 In general, masonry wall activities were found to be acceptable.
                         4. ' Concrete Expanr. ion Anchor Bolts
                         a.      Inspection Scope
                               -The qualification test-report for the wedge type concrete expansion
                                                                  ~
                                 anchors used at'the site was reviewed for technical adequacy,.
                               'conformance to the project specifications and demonstration of                            '
               ;                 satisfactory anchor performance.                                                         -
                                                                                                                          ,
                         b.      Inspection. Findings
                                The qualification test report was found to be consistent with the
                                 specifications and procedures for installation and inspection.                           1
                         c.     Conclusions
                                The concrete expansion bolt qualification test program was found to
                                be acceptable.
                         5 .~   Building Settlement
                    -
                         a.      Inspection Scope

, The-surveying data for Seismic Category I structures were reviewed

                                by the NRC CAT inspectors.and compared withLthe predicted maximum
                                settlement values shownlin Table 2.5.4 ~49 of the Millstone Unit 3-
                              .FSAR.
                                                                                                                          9

- "

                         b.     Inspection Findings
                                The building benchmarks are surveyed by.SWEC annually for founda-

'

                                tions'on bedrock-and semiannually for foundations on structural-
                                backfill.     The NRC CAT inspectors reviewed the settlement surveys.
                                conducted and found the survey frequency to be generally in com-

> f

           E
~_.-
                                                               V-6
~

, f

       ^
                                                                                      -,,,n.-.,.,n----<-~-,.m.- ww-wm --o
 _
   ,
     s
                                                 '
              pliance with the-field construction procedure.    It was noted that-
              Auxiliary Building benchmark 16 had been destroyed in late 1982 and
             -had'not been re-established. .The licensee has committed to estab-
              lish a benchmark-in the area of Auxiliary Building benchmark'16.
                        ~
             -The' Main Steam Valve Building, Containment Building and the Fuel.
              Building survey. data showed that, although these buildings were
              founded.on rock, the actual experienced building-settlements had
              exceeded.the FSAR predicted maximum values. -SWEC-geotechnical
              engineers indicated.the values are not indicative of actual settle-
            -ments but represent an accumulation ~ of survey errors.   This magni-
              tude of-survey error is reasonable and is well below levels of
            . structural movement that would cause concern to either buildings
              or interconnecting piping.
       - c.   Conclusion
            :The discrepancies batween'the recorded building settlements and the
             -predicted building settlements in tha FSAR are probably survey
              errors. Even.if the measurements were correct, the settlements
              were below levels of structural movement that would cause concern to-
              either buildings or interconnected piping.

,

 l

I

                                         V-7

e

,
                            ~ TABLE V-1
                         CONCRETE DRAWINGS
    Drawing No. Revision                             Subject
    EC-10G       7                        Control Building - Wall at-Line
                                          55 and Elevation 46'-8"
    EC-49P       5                       ~ Dome Details Sh'#2 Containment-
                                          Structure E&T
   .EC-50E       2                        Details Elev. 514 Sh #1 Contain-
                                          ment Structure Intermediate
                                          Concrete
    EC-50V       7                        Plan Elev. 51'-4 Outline
                                          Containment Structure Interme-
                                          diate Concrete
    EC-50Z       2                        Removable Concrete Shielding
                                          Plugs (RS-F, RS-B)
    EC-51G       5                        North Walls Elev. and Details Sh
                                          #1 Containment Structure Inter-
                                          mediate Concrete
   .EC-51J-      6                        North Walls Elev. and Details Sh

c._ #3 Containment Structure Inter-

                                          mediate Concrete
    EC-51P~      4                        Refueling Cavity Walls Sh #1
                                          Containment Structure Inter-
                                          mediate Concrete
    EC-750E      7                        Embedment Penetrations and
                                          Openings Floor EL 51'-4
                                          Containment Structure
    EC-751B      6                        Embedment Penetrations and
                                          Openings Containment Structure
                                          Walls Sh #2
    EC-751L'     3                        Embedment Details Containment
                                          Structure Walls Sh #4
                                V-8

nc .

                      -
                                                                                                  .. ;
                                                   '
                                                                                                    ;
                             -
                    ,                                                             .
                '
   ~,

'

                                            TALBE V-2
           ,
                                    STRUCTURAL STEEL' DRAWING 3
                           ^
 3              Drawing No.    Revision                               Subject
                 EC-731H1        2                         Eabedments, Penetrations and Openings
                                                           Details Main Steam Valve Building
    -
               IEC-751L:         3                         Embedment Details Containment
                                                           Structure Walls Sh #4-
               -_ES-3A;         10                         Operating Floor Framing Sh #1
                                                           Turbine Building (General Notes)
                ES-31H'          3                        ~ Framing Plans and Details. Main
                                                           Steam Valve Building
                ES-31J           3                         Framing Plans and Details Main ~
                                                           Steam Valve Building
                ES-31X           1                         Framing Plans and Details Main
                                                           Steam Valve Building                  ,
                ES-508           7~                        Annulus Platform Elev. 24'-6
                                                           Containment Structure
               .ES-50AD          2                         Reactor Containment Shield Door
                                                           Framing and Details Elev. 3'-8
                EV-56D           3                         Pipe Break Restraints FDW Bypass'-
                                                           Main Steam Valve Building Sh #1
      ,
                EV-56E           3                         Pipe Break Restraints FDW Bypass
                                                         ' Main Steam Valve Building Sh #2
        - .EV-132D               4                         Intermediate Structure Staam:
                                                           Generator Cubicle.-   Cubicle D-
                                                           Plan 28'-6
             -EV-132EE-          5                         Intermediate Structure Steam
                                                           Generator Cubicle Connection
                                                           Details Sh #1
                EV-132F '-       4                         Intermediate Structure Steam
                                                           Generator Cubicle Connection.
                                                           Details on SH #2
             .EV-132G.           4                         Intermediate Structure Steam
                                                          Generator Cubicle Connection
                                                           Details Sh #3
                                               V-9
 -
                        TALBE V-2'(Continued)
                      STRUCTURAL STEEL DRAWINGS
    : Drawing No. Revision                           Subject
      EV-132H       4                      Intermediate Structure Steam
                                           Generator Cubicle Connection
                                           Details Sh #4
      EV-132J      ~3                      Intermediate Structure Steam
                                          -Generator Cubicle Connection
                                           Details Sh #5
      EV-132K       3                      Intermediate Structure Steam
                                          ~ Generator Cubicle Restraint
                                           Structure Details
      EV-132LE      3                      Intermediate Structure Steam
                                           Generator Cubicle Restraint
                                           Miscellaneous Details
      EV-132M       3                      Intermediate Structure Steam
                                           Generator Cubicle Connection
                                           Details Sh #6

s .-

       4
                                V-10
   n:                      -        ,
                                  E
     '                 '
            :v e
               ,                                      ' TABLE-V-3-
      
                 ,                         . CONCRETE BLOCK' WALL DRAWINGS
        ,
                      LDrawing"No.      Revision;                               . Subject
          '                                                                                            ~
     '
                      'EA-1F                -12                      . Floor Plan Elev. 47'-6 Control
                                                                      Building Sh #2-
                      .EA-1E'            - 11 -
                                         .
                                                                    -Floor Plan Elev. 4'-6. Control
                                                                      Building Sh #1
                      CE A-90'                6'                      Masonry Details 9 Elev. 47'-6
                                                                      Control Building-
        "
                                -
                         ES-60F               2                       Block Wall: Bracing Elev. 47'-6-
   -
                                                                      Control Building Sh'#1
                      IES-60G-                2                       Block Wall Bracking Elev.c47'-6
                                                                      Control. Building Sh #2~
                         ES460H               2                       Block Wall Bracing Elev. 47'-6.
                                                                     Control Building Sh #3
                     JES-60J.                 2                      Block Wall Bracing'Elev. 47'-6--
                                                                     Control Building Sh #1-
                     ~ ES-60K'-               1-                     Block Wall Bracing Elevi 47'-6
                                                                     Control Building Sh #2
                     ' ES-60L:                2                      Block Wall Bracing Elev. 47'-6;
                                                                     Control Building'Sh #3
             _
                   F
       :b

e

 -

L.-

                                                         V-11

. ,

-

   ,
     ! VI .~ MATERIAL TRACEABILITY AND CONTROL ~
 ,           A.   Objective
                  The objectiveof this portion of the inspection was to examine trace-
                 -~
                  a bility and control'of material and equipment, and to determine the
                  adequacy of the licensee's program r' elative to these activities.
             B.   Discussion-
                iThe approach'to perform.the inspection was to identify-and select
                  samples of various' types-of installed material and equipment for exami-
                                                                   -
                  nation. -Some samples _of installed material, such as _rebar, that were -
                cnot accessible were selected from records. Also, some samples of
                ' delivered material, such as protective ' coating materials, not yet
                  installed, but-inspected in warehouses or shops, were included. A total
                  of 297 samples were examined to varying extents.
                ' Applicable organizations and procedures for various activities were
                  reviewed. 'The following Stone & Webster Engineering Corporation (SWEC)
                  procedures were reviewed:
                  *
                       NEAM 3,-Rev. 10, Specification Inquiry and Purchase
                         Procedure, Change No.-3
                  * - CMP No. 1.12, Rev. 3.79, Material / Equipment Maintenance
                       P-CMP 1.2,1Rev. O, Receiving Material and Equipment
                  *
                              ~
                       P-CMP 1.3, Rev. 3.79, Material / Equipment Storage,
                         Change No. 3
                  *
                       QS-7.1ML, Rev. O, Receiving Inspection, Change No. 3
                  *-   QCI No. FM3-S7.1-070, Traceability Requirements
                  *
                       FCP-121, Rev. 5, Equipment' Storage History Card
                  "
                       FCP-354, Rev. O, Transfer of Traceability Markings
                         on Plates and Shapes

~

                            -
                 An inspection of installed material and equipment was conducted in the
                  plant to select and verify markings on various ' samples, such as equip-
                 ment (mechanical, electrical and instrumentation),. pipe, supports /
                  restraints and weld' joints. Other samples were inspected in warehouses
                  or shops. Table VI-1, " Summary of Samples," indicates the types and
                ' quantities of materials examined. Table VI-2, " Weld Filler Material
                  Compliance," contains a list of the 39 weld filler material samples
                  selected.
                                                 VI-1
                                                       =-             -   -
E.                                                                                                   >
                                                                                                   n
   -1. : Material Traceability and Control
     a.   Inspection Scope
 '
          A total of 297' samples were selected and examined for traceability
          to applicable-drawings, specifications, procurement records, certi-
          fied material: test reports (CMTRs), certificates of compliance
          (C of Cs)~, heat numbers or other required documentation.
     b.   Inspection Findings
   ^
          In general, it was found that satisfactory procedures were in place
          for material traceability and for control of material at the site.
        'Except for a lack of traceability for certain fastener materials,
         .the material traceability program was found to be generally accept-
         able. The following observations were made by.the NRC CAT inspector:
          (1) Manual and computerized records were used to help control the
                identification and status of material and equipment at the
                site.
          (2) Thirty-nine samples of weld filler materials listed in Table
                VI-2 were examined for traceability and compliance with speci-
                fications and codes, and were found to be acceptable.
                Twenty-five weld filler material holding ovens in two issue
                stations were examined and found to meet requirements for
                temperature control and thermometer calibration records.
        -(3) NRC IE Information Notice No. 85-15 described a problem regard-
                ing the identification and marking of ASTM A-36 steel plate
                material supplied by Interstate Steel Supply Company and noted
                that this firm had supplied material to Millstone Unit 3.-The
                NRC CAT inspector inquired as to the control of Interstate
                Steel as an approved vendor, the quantity of material supplied,
                applications of the material, and the status of the licensee's
                action relative to this matter.
                An interim response from SWEC to Northeast Utilities Service

,

                Company (NUSCO) dated March 8, 1985 stated that 175,347 lbs. of
                A-36-plate (cut pieces) had been furnished by Interstate Steel.
                It was noted that early orders were for Category II applica-

i

                tions, but that one order (P.O.08766 dated October 4, 1979) was

'

                for Category I applications.           A review of the status of Inter-
                state Steel as an approved vendor revealed that a February 1980
                evaluation resulted in removing this firm from the approved
                list for Category I material because of material identification
                and documentation problems.           Interstate Steel was reinstated as
                an approved vendor for Category I material as a result of a
                survey in March 1980, and subsequent surveys resulted in
                retaining this firm on the approved list.
                Only one piece of A-36 steel plate material supplied by Inter-
                state Steel that had not been installed could be located. This
                sample was_found in the pipe hanger fabrication shop.              The
                                         VI-2
             ..        - - - - _ - - - .      . . - .     - . -      . -    .  . -     . . . . - .

.

                      m
               lN -
     9       1
           #
               '                                          ~
                              ; markings. stamped on this' sample were traceable to the appro-
                                .priate certified material test report. No discrepancies were
                                 noted.-
          c.                   'SWEC representatives stated that their review and examination
                                 of records'related to NRC IE Information Notice No. 85-15 was
                               . continuing.
         -
                        . (4); Material an'd equipmentflisted in Table VI-1 were examined for
                    ^
                                 traceability and control. Most items examined were found 'to
                                 have the required material traceability; however, some .defi-
                                 ciencies were found regarding the traceability and control for
                               11arge motor mounting bolts and other fastener materials as
                                 follows:
                                 (a) Equipment mounting bolts for 10 of 49 fastener installa-
   -
                                      tions examined were found to have-unmarked bolts and thus
                                      the bolt material was' indeterminate. The 10 instances of
                                      unmarked mounting bolts were for motors for the' following
                                      pumps:
       ,
                                            Quench Spray Pumps (3QSS-P3A, B)
                                      *~ Safety Injection Pump (3SIH-PIB)
                                     ~ * Chemical Volume Control Pumps (3CHS-PIA, B;-P3A, B, C)
                                          -
                                      *ComponentCoolingChargingPumps(3CCE-PIA,B)
                                         .
                                     ~As a result of these CAT findings, the licensee issued
                                      Nonconformance~and Disposition Reports (N&Ds) 11765, 11767,
                                      11904, 11905 and-an UNSAT Inspection Report (IR) M5A51085
                                      to initiate corrective actions. Also,.a Report of a
                                      Problem-(R0AP), " Unidentified Bolting Material on Vendor
                                      Supplied Equipment," was issued March 14, 1985, to initiate
                                      reviews for generic and reportability aspects.
 '
                                 (b) Battery rack assembly bolts (specified to be ASTM A-307 in
                                      the seismic-qualification report) in the five battery
                                      rooms in the Control Building were inspected. It was found
                                      that 282 of 700 bolts (approximately 40%) were unmarked
                                     1(not. meeting ASTM A-307 requirements) and thus were'of
                                      indeterminate material.
                                      As a~ result of this finding, the licensee issued N&D 11498
                                      for corrective' action. Subsequently, the licensee selected
                                     - samples of unmarked bolts from each battery room for
                                     -testing by Bridgeport Testing Laboratory. Testing showed
                                      all 97 bolts tested to conform to ASTM A-307 material
     .
                                      specifications. N8D 11498 was dispositioned " Accept as
                                      is."
       .
                                -(c) For four motor control center (MCC) interconnections
                                      examined, all four had unmarked bolts for connecting
                                      adjacent cabinets and thus were of indeterminate material.
                                       It was noted that 20 such-cabinets were furnished by Gould,
                                       Inc. .The specified bolting material was SAE Grade 2 which
                                      requires at least the manufacturer's identification
                                      marking.
                                                            VI-3

,

                As a result of this finding, the applicant issued E&DCR
               -T-E-03663.   In reviewing this document, NRC CAT inspectors
                concluded.that the response shows a lack of thorough-
                ness on the part of.. site engineering, in that.the response
                indicates that the bolting material is SAE Grade 2 without
                adequate techical justification. Since the bolt markings do
                not meec.the requirements of SAE Grade 2, the material can
                only be considered to be indeterminate.
                NRC CAT inspectors concluded that the use-as-is response
                indicated on E&DCR T-E-03663, is not adequate to assure
                that fasteners used in the assembly of MCCs are the
                specified SAE Grade 2 material, and that further licensee
                action will be required to resolve this issue.
    '
           (d) Bolts for mounting Control Board Termination Cabinet
                (3CES*TBMB30) were unmarked, and thus material was indeter-
                minate. The applicant-issued UNSAT IR ESA01843 to' initiate
                review and corrective action.     This appears to be an
                isolated case.
 c.   Conclusions
      In general, except for certain fastener hardware, the material
      traceability and control program was considered to be satisfactory.
      Significant lack of traceability was found for fastener materials,
      including bolts for mounting large pump motors, bolts for battery
      racks and bolts for interconnecting adjacent MCC cabinets.
                                  VI-4
      -                        =     ~    '
                                              y'                   ~
                                                                                      _,,
,,
    n
  .N
   '
_
                                                   TABLE VI-1
                                               SUM 4ARY OF SAMPLES
                    Item                                                  .No. of Samples
             -Equipment                                                         25
              Pipe                                                              22 (L)*
           - Tubing-                                                              9 (L)
              Steel-Structural                                                  10 (L)
              Steel-Rebar                                                       10 (L)
              Steel-Plate                                                       10 (L)
              Steel-Tube                                                        10 (L)
             . Hangers / Supports / Restraints                                    3
              Embedments                                                          4
              Inserts (Richmond)                                                  4 (L)
              Insert Studs (For Richmond Inserts)                                 4 (L)
              Weld Filler Material                                              39 (L)
              Weld Joints                                                       25
              Electrical Cables (Reels)                                         27 (L)
              Fasteners (Sets)                                                  49 (L)
              Cadweld Sleeves                                                   28 (L)
              Coatings                                                            5 (L)
              Unistrut                                                            5 (L)
              Raceway                                                             3 (L)
              Shims                                                               5 (L)
                                                                     TOTAL     297
        *(L) = Lots
                                                      VI-5
                                                                                          1
                                . - . . .        .        _
                                                                     .--- ._-- __ -_ --_- - _- _ _ __          _ _ _ - _ _ _ _ _ _ _
  ,
         x
  '
     Y
               ,
                                                      TABLE VI-2
           ., ,;
       .                                  WELD" FILLER MATERIAL COMPLIANCE-
                     ' Material                      Heat'No.'/                                 Compliance
 '
                    Designation-                     Material---ID                                    Comments
                    E1001802:1/8                     Lot'5043A49144                            Acceptable
    '
                    ENicu-7 3/32                   -8M12C Mix 23'                         -Acceptable
                 -806-9N10'1/8                      8K22B Mix 14                               Acceptable
                 ~.ENicu-7 1/8                       10678-1-3                                 Acceptable
                    E308-16 1/8                      5E17B Mix 7                              Acceptable
                    E7018 3/32                     '411A0952                                  Acceptable
                  -ENiCrFe3 1/8                      Lot 10748-1                              Acceptable                             1
                    E309-15~1/8                      Lot 11501-1                              Acceptable
                    E309-15 1/8                      Lot 11631-1                              Acceptable                             i
                    E7018 1/8l                      8215                                      Acceptable
                    E316L-16 1/8                    782860                                    Acceptable
                    E308L-16 1/8                    782815                                    Acceptable-
                 - E308L-16 3/32
                  .
                                                    761127                                    Acceptab1_e~
                    E316L-16 3/32                   743528                                    Acceptable-
                    E309-16 3/32                    743202                                    Acceptable
                    E309-16 1/8-                    743880-                                   Acceptable
  ,
                    E316-15'1/8                     Lot 10499-1-1                             Acceptable
                    E316-15 3/32                     Lot 50148-1                              Acceptable
                    E308-16 3/32-                   Lot SK13A Mix 29                          Acceptable
                    E308-16 3/32                    Lot SM2A Mix 29                           Acceptable
                 .E316-16 3/32                      Lot SF7A Mix 28                           Acceptable
                    E8018G 1/8                      48348                                     Acceptable
                    E8018G 3/32.                    48429                                     Acceptable

!

                                                          VI-6
                                                      '
 .
       e

L

                                    l TABLE VI-2 (Continued)
                               -WELD FILLER MATERIAL COMPLIANCE
     .       ~ Material                   Heat No./-             Compliance
         : Designation              -
                                          Material ID             Comments
           E308-16 1/8                    Lot SK98 Mix 10        Acceptable-
           E308-16.3/32                   Lot SG16A Mix 19       Acceptable
   .
                                               ~
           E30s-16 1/8                    Lot CX                 Acceptable
            E309-16 3/32'                ' Lot 90151-1           Acceptable
            E7018 3/32                    411X4302               Acceptable
                                          22768                  Acceptable--
                                 '
            E9018-B3.1/8
            E9018-B3 3/32                 39586                  Acceptable
            E9018-B3 3/32                 39610                  Acceptable
            E8018-C1-1/8                 '421T2133               Acceptable
            E8018-C1 3/32                 421T2133               Acceptable
          ' ER309.3/32                    Lot C2970E308         . Acceptable
         : EB Weld Insert 308L 5/32        Lot E2267-308L        Acceptable
            E308-16 1/8                   Lot SE17B              Acceptable
            E7018 3/32                    411A0952               Acceptable
            NiCrFe-3 3/32                  Lot 50225-1           Acceptable
            E7018 3/32                    402A9061               Acceptable

l r a

                                                 VI-7

i;

VII. DESIGN CHANGE CONTROL

    A.   Objective
         The primary objective of the appraisal of design change control was to
         determine whether design change activities were conducted in compliance
        with regulatory requirements, Safety Analysis Report (SAR) commitments
         and licensee, architect engineer, and constructor procedures. An
         additional objective was to determine that hardware modifications
         described in a sample of design change documents were properly imple-
        mented in the field.
    B.   Discussion
         10 CFR 50, Appendix B, Criterion III " Design Control" and Criterion VI
         " Document Control" establish the overall regulatory requirements for
        design change control. These requirements are elaborated in Regulatory
        Guide (RG) 1.64 " Quality Assurance Requirements for the Design of
       ' Nuclear Power Plants" and American National Standards Institute (ANSI)
        Standard N45.2.11-1974 " Quality Assurance Requirements for the Design
        of Nuclear Power Plants." The licensee's commitment to comply with RG
         1.64 is stated in Appendix D of the Northeast Utilities Quality
        Assurance Program (NVQAP) Topical Report.     Stone and Webster Engineering
        Corporation's (SWEC) commitment to RG 1.64 is stated in Appendix VII of
        the Quality Assurance Program Manual for Millstone Nuclear Power Station
        Unit 3 for construction activities.
        The areas of design change control evaluated in this inspection were
       . control of design documents and control of design changes. In each of
         these areas, interviews were conducted with personnel responsible for
         the control of activities, procedures were reviewed, and a sample of
        controlled documents was reviewed. In addition, a sample of the com-
        pleted structures and hardware wMch had been inspected and accepted by
        Field Quality Control (FQC) personnel was verified in the field for
        compliance to design change document requirements.
        1.   Control of Design Documents
             The key aspects of this inspection were to determine if sufficient
             site controls existed to assure that the latest design documents
             and design change documents were available for field use in a
             timely manner, and that the latest documents were actually available
             in the field,
        a.   Inspection Scope
             (1) Design document control for drawings, installation / erection
                   specifications and Operating, Installation and Maintenance
                   (0IM) manuals was evaluated from the point of engineering
                   issue to the point where these documents were considered
                   working documents for field construction and FQC acceptance.
                   Control of Engineering and Design Coordination Reports (E&DCRs)
                   and availability of E&DCRs, Nonconformance and Disposition
                   (N&D) reports and Vendor Information Requests (VIRs) at
                   selected drawing stations were also evaluated. The major
                                         VII-1
    R*^
                     -
                           ,
               ,       . N
      '
                                    ' emphasis was1to determine if the correct revision of documents
                                    , including applicable changes were available in the field based
                   -
                                     on the master records. Document Record Cards (DRCs) for 69
                                   Ldesign documents and some of the associated E&DCRs/N&Ds/VIRs
         ~                                   -
   ..
   '
                                     were reviewed at six site drawing stations. Sixty-seven DRCs
                                     were also reviewed at the FQC drawing' station. In addition,
                                     control of 10 specifications and.12 OIMs was reviewed.
                             :(2)'. Document control audit plans, attributes, reports and
                                    = responses, surveillance reports as well as' Interoffice Office
                                    : Memorandums discussing document control : findings were reviewed.
                                     These documents were evaluated for relevancy of attributes,
                                                       -
                                     sample sizes, proper audit methods, trends, frequency, and
 l
                                     corrective actions'for. assurance that.the latest design docu-
                                     ments were being used for field work and-QC. acceptance. Six
                                   -FQC monthly drawing ' station audits.(each' covering 100% of-
                                  - change documents issued for one week out of each month), 5
       '                                                 -
                                    ' weekly FQC drawing station surveillances', and 4 Boston Quality
           '
                                     Assurance Auditing Division (QAAD) audits of site document
                                     control were-reviewed.
                 .
                              (3) SWEC Engineering and Construction Document Control, FQC, and
                                     Boston QAAD personnel were interviewed concerning distribution,
                                     control and use of design and design change documents, and.
                                     document control audits and surveillances.
                              (4) The'following procedures relating to control and distribution         {
                                     of design documents were reviewed:
             9
                                     *                                                                  '
                                          SWEC Engineering Assurance-Procedure (EAP) 4.13, " Processing
                                          ofProjectSpecifications,"Rev.O, Change 6LR.
                                     *
                                          SWEC EAP 5.4, " Review and Approval of Project Production
 ,
                                         . Drawings, Rev. 3, Change 7
                                                    -
                                     *
                                          SWEC EAP 6.1, " Document Control," Rev. 1, Change 5-
                                     *
                                          SWEC EAP 5.8, " Review of Supplier Drawings," Rev. 1,
                                          Change 2
                                          SWEC EAP 6.5, " Preparation, Review, Approval and Control of
                                          Engineering and Design Coordination Reports (E&DCRs) -
                                          Computerized Logging and Tracking System," Rev. O, Change 1.
                                          SWEC EAP 9.2, " Review and Approval of Supplier Technical
                                          Documents," Rev. 4, Change 6
                                     *   -SWEC Construction Methods Procedure (CMP) 11.1, " Job Site
                                          Document Control," Rev. D
                                     *
                                          SWEC NEAM 3, " Specification Inquiry and Purchase Proce-
                                          dure," Rev. 10, Change 4
                                     *
                                          SWEC NEAM 5, " Supplier Document Handling System - IS 249,"
                                          Rev. 9, Change 1

.

                                                            VII-2

y ,

                *
 1                  -SWEC NEAM 19, " Handling, Review and Distribution of SWEC
                     Production Drawings," Rev. 11, Change 0
                *
                     SWEC NEAM 32, " Supplier Technical Document Review and
                     Distribution Millstone 3 - NUSCO," Rev. 9, Change 0
                     SWEC NEAM 38, " Authorization of Engineering and Design
                     Changes," Rev. 8, Change 4
                     SWEC Quality Control ~ Instruction (QCI) FM3-S14.2-06, " Site
                     QA Program Monitoring," Rev. A
             ~
                   = SWEC QCI FM3-56.1-04, " Drawing Control Verification," Rev. 0
     b. Inspection Findings
        (1) A random sample of 69 DRCs obtained from the master DRC file in
               construction document control was taken to drawing stations 12,
               33, 34, 62, 138, and 143 and compared to the documents filed at
               each station. A DRC exists for every plant drawing and lists
               all applicable E&DCRs, N&Ds and VIRs for each drawing as well
               as showing the latest drawing revision. The DRC, drawing,
               E&DCRs, N&Ds and VIRs are required to be checked by construc-
               tion personnel for correct drawing revision and applicability
               of outstanding E&DCRs, N&Ds and VIRs to the specific work area
               prior to construction work. CMP 11.1 is the governing
               procedure for site drawing station controls. Associated with
               the 69 DRCs reviewed, 69 drawings, 79 E&DCRs and 37 N&Ds were
               also checked at the stations. Fifty-one document' control
               errors contrary to CMP 11.1 requirements were noted as follows:
                      3 DRCs not current
                      1 missing DRC
                     11 missing E&DCRs
                      7 missing N&Ds
                      4 missing drawings
                      2 drawings at same station had 2 different revisions
                      3 improper voidings of E&DCR or DRC
                     20 DRCs with missing descriptive summaries
               See Table VII-1 for specific drawing numbers and summary.
        (2) FQC has its own drawing station (number 31) which is con-
               tinuously staffed with an attendant unlike the field drawing
               stations used by the crafts. Because of the high error rate
               noted at other site drawing stations, the FQC drawing station
               was looked at separately for non-current and missing DRCs only.
               Document control errors contrary to CMP 11.1 requirements were
               found. Out of 67 DRCs checked, 6 were not current and one
               was missing.     This error rate was considered of particular
               significance since the FQC station provides the documents used
               for acceptance of plant construction. Table VII-1 lists the
               DRC numbers checked at station 31.
                                       VII-3

L

ma --

                                         ,
    )     A' >      ,                                  .{.
                  -                        -
                                                                                                      -!
                             ~(3) LIncluded above are two cases'in which the back of thelDRC=
                                                              .
                                  = copy" reflected information which did not apply'to the-drawing
 ,m                                 specified on the front. --The back sides of the master DRCs were
         ~
                                    not annotated with the drawing. number so applicability of the
                        .
                                   .information on the back could not be verified with the front.
                                  iApparently a mixup had occurred in copying of the DRCs. This
                                  ' problem-had also been noted previously.by document control-
  g                   '
                                  : personnel and the DRCs known to be incorrect were recopied.
                                    However, no corrective actions had.been taken to. identify the'
                  '.                back side of DRCs with the document number to preclude
                                    undetected copying errors. This.is considered to be inadequate.
                                    corrective actions by Construction Document Control.
                            - (4).Yellowdrawingswerenotbeingdatestampedwhencopiedand
'
                                    provided for.use. These drawings.are uncontrolled but are
        '
                                    used as information. copies for construction. The drawings are
                                    considered acceptable for use on the. day of issue only, unless
                                    reverified and initiated by the user. Since the drawings were
                                  .not date stamped it could not~be determined when the drawings
     -
                                   .were issuedLand that proper reveritication had occurred prior
                                    to use. The lack of a requirement for date stamping of yellow
                                    drawings when. copied is considered to be a procedural weakness
                                    in CMP 11.1.
                            . (5) Control of specifications was evaluated for a random sample of
                                    ten specifications. One control point for each specification
                                                                                  t
                          .         was checked to determine if latest addenda and revisions per
                                    the Engineering Document Control Specification Index were
                                    received and filed. Numerous errors were noted as follows
                                    contrary to NEAM 3 and CMP 11.1 requirements:
                                    *
                                        -Two cases of the latest-specifications revisions and
                                        ' addenda were found not filed in the specification books.
                                          The specification revisions were located in a stack of'
                                          documents to be filed. . The superseded specifications,
       '
                                          revisions and addenda were filedLin the specification-
                                          books.
  4
                                    *
                                          In one case the Engineering Document Control Specification    !
                                          Index did not indicate the. latest addenda.
                                    *
                                          In one case the entire specification was missing-from the
                                          file book but was later located.
                                    *
                                         Two cases were noted of E&DCRs not being filed.    They were
                                          also located in a stack of documents to be filed.
                                    *
                                         One case was found of E&DCRs being filed by date received
                                         and not by E&DCR number such that retrievability of
                                          specific E&DCRs was very difficult.
                                    *
                                         One case of E&DCR posting errors.
                                    See Table VII-2 for document numbers and summary.
  '
                                                           VII-4

v; c a; s .

  .
     I
 *
               (6) Control of 0IMs was' evaluated for a random sample of twelve
                        OIMs.     The following' problems were noted contrary to NEAM 32
    M
         '
                        and CMP 11.1 requirements:
                     ..
                        * - The index in Engineering Document Control did not indicate
                             <the latest manual revision in one case.
                        *-
                              The record log.in Construction Document Control did not
       x                       have-al1 the applicable E&DCRs posted in two-cases.
                    :*
                              .The IS-305, system had two data entry errors in one case.
                        Even though the above problems were identified, all 12 of the
           '
                        manuals on the shelf were the latest revision and had the.
                        applicable E&DCRs filed with them. See Table VII-3 for docu-
                        ment numbers and summary.
               (7) .In the area of document contro.1 audits, it was found that                l
                        audits were generally being accomplished in accordance'with
                        requirements. In fact, audits and surveillances-had been-
                                                           -
                        increased within the past year due to the number of errors
                        found'at drawing stations by various auditing activities.
                        Just prior'to the NRC CAT inspection, a 100 percent audit of
                        all drawing stations was performed by FQC. This audit covered
                        186,706 drawings and DRCs.       However, as the NRC CAT identified
                        discrepancies.in document control have shown, the audits did
                    -not identify the underlying problems'and were considered weak
                        for the following' reasons:
                        *'
                              The FQC monthly audits were not using the master DRC or
                              engineering computer data a'vailable for determining l latest
                              drawing revision numbers or applicable drawing changes.
                    ~"
                             .There had been no specific audit attention given to speci-
                              fications or 0IMs for the past two years. In view of
                              the' errors found in this inspection additional attention
                              is warranted.
                        *
             ,                Boston QAAD audit reports were not sufficiently detailed
                              to allow determination of how document control audits were
                              conducted.    Audit attributes also lacked sufficient. details-
                              for conducting thorough, consistent and uniform document
     ,
                              control audits.
                        *
                              Although Construction Document Control-had accomplished
                              some self audite at specific stations when errors were
                              identified, there was no formal plan for accomplishing self
                              audits and taking permanent corrective actions on an
                              overall basis. In view of the continuing drawing station
                              errors being identified, Construction Document Control
                              should have been determining and resolving their problems
                             much sooner. This is considered to be inadequate correc-
                              tive actions ~by Construction Document Control.
                                                VII-5

e

c. Conclusions

  Although the basic system framework for design document control
  appears to be adequate, a large number of errors were found to exist
  in site document control in spite of increased attention the past
  year.    The actions taken to date have not been effective in properly
  maintaining drawing stations and improving document control. Audits
  and surveillances have not been effective in identifying problems
  and root causes.      Considering the above, document control needs
  special attention to resolve the underlying problems and to reduce
  the error rate to an acceptable level.
  Two cases of inadequate corrective actions in document control were
  noted. These are discussed further in Section VIII-B.1.b(4).

2. Control of Design Changes

  The specific aspects of this inspection were to determine if effec-
  tive measures were present for control of design changes, that
  these measures were being followed and design changes were properly
  implemented in the field in accordance with design change require-
  ments.

a. Inspection Scope

  (1) The principle method of accomplishing design changes is by
        E&DCR.    Other methods not included in this inspection were
        use of N&Ds and VIRs or direct design document revision.
        Approximately 45,000 E&DCRs have been issued for construction
        at Millstone 3. About 200 random E&DCRs were reviewed in this
        inspection for conformance to site procedures including need
        for the E&DCR, need for design change, clarity of problem
        desciption and solution, reasonableness of solution, technical
        justification for design changes, appropriate reviews and
        approvals, and reference to calculations when appropriate.
  (2) Supporting calculations associated with eight E&DCRs were
        reviewed for conformance to site procedures including
        retrievability, clarity, cross referencing between the calcula-
        tion and E&DCR, general neatness and basic approach.     Also,
        calculation controls were reviewed.
  (3) Incorporation of design changes by E&DCR into parent documents
        was evaluated for conformance to site procedures. Forty-six
        design documents (i.e. drawings, specifications or 0IMs)
        designated to be changed because of E&DCRs were reviewed to
        determine if each document had been revised to incorporate
        E&DCR requirements or was within the control system for
        eventual incorporation of E&DCR requirements. At the time of
        the NRC CAT inspection the site requirement was to revise
        drawings within four months after the sixth "to be incorpora-
        ted" change document was issued.
                               VII-6

4 .a s

        .
                                  <          '
-               o
                     . (4) ..The Project' Change. Request (PCR)-and Westinghouse Field Change-
                              . Notice (FCN) systems were evaluated for conformance to site
                               procedures including proper control of design changes imple-
      ,
             -
                             -mented:via-PCR or FCN. ' Site procedures-require that-design-
  1                          ichanges cinitiated by.either.PCR or FCN be implemented by E&DCR.-
                                         ~
    ~
                        (5) -Design' control audit p1ans,' attributes and reports.were
                                       -
                               reviewed.-for relevancy of attributes, sample sizes, proper
                             .. audit methods, trends, frequency and corrective actions for
                               assurance that proper design change control procedures were.
                              :being followed. Three SWEC Engineering Assurance (EA)' design-
                               control audits and two EA technical audits were-reviewed.
                        (6) A random sample of 16 E&DCRs for which work was completed and
                               FQC' accepted were inspected in the field to assure E&DCR
                              . requirements had been' implemented.
                       -(7) Various SWEC engineering discipline and principal engineers as
                               well as FQC personnel were interviewed concerning E&DCRs,
                               calculations, audits, programmatic controls and hardware
                               installations.
          -
                       '(8) The following procedures relating to control of design changes
                               were reviewed:
                               *
                                    SWEC .EAP. 3.1, " Verification of Nuclear
                                                                     '
                                    Power Plant Designs," Rev. 2,- Change 5
                               *
              ~
                                    SWEC EAP 5.3, " Preparation and Control of Manual and
                                    Computerized Calculations (Nuclear Projects)," Rev. 3,
                                    Change 3
                               *
                                    SWEC EAP 5.4, " Review and Approval of Project Production
                                    Drawings," Rev. 3, Change 7
                               *
                                    SWEC EAP 6.5, " Preparation, Review, Approval and Control of
                                    E&CDRs - Computerized Logging and Tracking System," Rev. O,
                                    Change 1
                               *
                                    SWEC NEAM 38, " Authorization of Engineering and Design
                                    Changes," Rev. 8, Change 4
                               *-
                                    SWEC NEAM 41, " Processing of Calculations," Rev. 6, Change 9
                               *
                                    SWEC NEAM 68, " Handling of Nonconformance and Disposition
                                    Reports by Engineering and Design," Rev. 6, Change 0
                              -*    SWEC NEAM 83, " Vendor Information Request," Rev. 3, Change 3

7

      ,           b.    Inspection Findings
                        (1)    In general E&DCRs appear to be used as intended by site proce-
                               dures.      Review of a random sample of approximately 200 E&DCRs
                               identified the following discrepancies:
                                                                                                  .
                                                        VII-7                          *

es j. -

     ,  g
       %

^

 ,         y
       n
    .
                            *
                                iNo technical justifications were provided for five E&DCRs       i
                                 :(FP 35766,'FB 39126,.FC 39127. FE 35758, FE 33638) as-         '
     F               7          frequired by Revision 8 to NEAM 38.-
                            *
                                  F.1;17774 was not dated by the Project Engineer when signed-
                       ^
                                  as required by NEAM 38.
                     (2) f A significant number of design documents were found to be over '
                  '
                            due for updating by the 6 and 4 rule as required by NEAM 38..
               -            Forty-six design documents associated with E&DCR changes were
  ,
                            reviewed to see if they had been revised or were in the
                            tracking system. The results were as follows:
                                                                                               '
                            *
                                  All 46 were being tracked in the IS-305 system.
                            *
                                  Eight had already been revised and listed the E&DCR numbers
                                  in the revision columns.
                            *
                                  Nine of the 46 had more than 6 E8DCRs and 4 of those were
                                  overdue for revision (i.e. overdue by 6 and 4 rule).-
                            *
                                  Upon additional review of all plant drawings with "to be
                                  incorporated" E&DCRs outstanding, it was found that 421
                                  drawings had reached the 6 and 4 requirement and 35 percent'
                                  of those were at least one month overdue.
                            *
                                  It was noted that'in October 1983 there were approximately
                                  40 documents overdue for revision, in December 1984 there
                                  were about 80 overdue and in March 1985 about 150. Even-
                                  though a list of drawings that had reached the 6 and 4
                                  requirement was published monthly and subsequently discus-
                                  sed at management meetings, the number of overdue documents
                                  continued to increase. This appears to be a case of'
                                  inadequate corrective actions to reduce the number of
                                  documents overdue for revision.
                     (3) A lack of followup and implementation of corrective actions
                            associated with the NRC Region I~ Construction Team Inspection
                            (CTI) Report 50-423/84-04 of May 30, 1984 was noted. The CTI
                            finding addressed the need to relate implementing EADCR numbers
                                                          SWEC had changed the governing
                            backtooriginating)PCRs. procedure -(NEAM 117 to accomplish the new
                            revised procedures had not been implemented. Otherwise, the PCR
                           :and FCN processes evaluated in this inspection appeared to be
         ,
                            in confonnance with site procedures.
                    - (4) Of the eight engineering calculations reviewed in detail, no
                            discrepancies were noted relative to site procedures. The
                            calculations were retrievable, clear and appeared adequate.
                            The logging and control procedures also appeared adequate.
                     (5) The EA audit program for assessment of site design change con-
                            trol implementation appeared to be quite thorough and was con-
                            sidered satisfactory.
                                                    VII-8
                                                              _ . _ .
                                                                       . _ _ _ _ _ _ _ _ _ _ _ -
  (6) The 16 E&DCRs reviewed in the field were satisfactory from a
        design change process standpoint. However, three of the 16
        checked did have implementation problems from a construction or
        FQC standpoint.  These three (TJ 1036, FP 22607, FB 33829) are
        discussed in Section III.   The other 13 E&DCRs (FE 33638, FC
        34777, FJ 34743, FJ 34710, FJ 35220, FJ 34265, TS 1258, TJ
        1096, TJ 1021, FE 39121, FJ 35703, FE 39107 and FP 23624) were
        found to be satisfactory in the field.

c. Conclusions

  For the sample inspected, there is adequate control of the design
  change process with the exception of updating design documents with
  the latest change information. Considering the number of E&DCRs
  that are outstanding against design documents, the potential for
  errors would be significantly reduced if design documents were
  updated in a timely manner. Management attention needs to be
  directed in this area.
  Two cases of inadequate correction actions in design change control
  were noted.   These are discussed further in Section VIII-B.1.b.(4).
                               ,
                            VII-9
                    - - _ - _ _ _ _ _ _ - _ _ _ _ _ _ - - _ _ - _ _ _ _ _ _ . _-- _ - _ _ .                                                                   . _ _ .        . - - _ _ _ - _
<

t-

                                                                                                         ,
              ,

. .

                                                                                                                     TABLEV{I-1
                                                                                                                                     s
                                                                                                  DOCUMENT RECORD CA,RD              g AUDIT SUMARY
                                                                                                                                          -
                                                                                                                               ^

,. ' ' Drawin(1

   '
             DRC/Drawine #                                                                  E&DCR #-                N&D'#                       Station W                 Discrepancy

b !- BE-52BC- 333 31

                                                                                                                            ~'
             BE-52GC                                                                                            ,
                                                                                                                                                33,31                  missing summary       *
                                                                                                                                                                 '
                                                                                            FE40552                      - ,

i FE39053 '

                                                                                            FE34149                                                                    missing 9 33
                                                                                                                                              '~

(/ ' EB-39P ~33, 31

                                                                                            FB37429                                            .,
                                                                                            FB36108

,

             EB-39N                                                                                            -                                33,31
FB36328 missing summary
                                                                                            FB37429
                                                                                            FB36954                                                                    DRC voiding error
             EE-34L                                                                                                                    ,
                                                                                                                                            '
                                                                                                                                                33,31                  DRC not current
                                                                                                                                         "
                                                                                                                                                                       & 31.(back to:
                                                                                                                                                                       back printing
                                                                                                                                                                       problem);
                                                                                                                                                                       missing summary
         .
             EE-34M                                                                                                       ,
                                                                                                                                   '
                                                                                                                                                33,31
                                                                                                                             '

! EE-34N .. 33,31 DRC not current 9

                                                                                                       '                                                               31 (back to back

'- printing problem);

                                                                                                                                                                       2 missing summaries
                                                                                                                                                                                             ~
             EE-34P                                                                                                                            33,31                  '2 missing summaries
                                                                                                                        '
             EE-34Q                                                                                                                            33,31         .[                              .
             EE-34R                                                                                                                            33,31
     '                                                                                            '
             EE-51C                                                                                                                            33,31                                         ;

, FP35373' , '

       ,                                                                                    FP33149
                                                                                         :
                                                                                            FE32650                                                 1                  E&DCR not voided
                                                                                                                                           33,31
             EE-34AV
                                                                                                           '
                                                                                            FE27135
                                                                                                                  -

l FE18930

                                                                                            FE.6361
                                                                                                   .
                                                                                    p
                                                                                                                                 9

L , VII-10 - I !

                                                                                             ~~ '
 a
                                                                 -
         ,                   .
   qip
       '
                                   . TABLE VII-1 '(Continued)
                               DOCUMENT RECORD CARD AUDIT SUMARY
     ,
                                                            Drawing-
         LDRC/ Drawing #. E&DCR #         N&D #            Station #.   Discrepancy
          '
         :EE-34DL                                         :33         2 revs at station
            EE-34JB                                        33         2 revs at station
           - EE-34BE--                                     33,31
                                                              '
                                                                          ..
                          FE29279                                     missing
                          PE7161                                      E&DCR marked void
         ~ EE-34JCl                                        33,31
                                         -10349
                                          9720
                                          8070
   '
            EB-15Y                                         143,31
                          FP39301
                                          5904

, FJ17866

            ES-318L                                        143,31     DRC not current @ 31
                                          10631
                                          4879
                                          4968
            ES-31D.                                        143,31
                                         5025
                                         4304                                                  o
                          FS26024
            ES.-31E.                                       143,31
                                         5904                                                     '
                          FS23123
                          FJ15645
            BZ-501A-1                                     143,31.     DRC not current 9 143;     l
                                                                      4 missing summaries'
                                         11078                        missing
                          FJ40308
                                         9837-
                                         9230
                          FJ34694
            BZ-515G-1                                     143,31      DRC missing @ 31
                                        '10925
                                         10683
                          CJ3035
                                             VII-11
              ___
                   . _ - - _ _ _ _ _ _ _ _ _ _
 _
                                                        TABLE VII-1 (Continued)
                                                   DOCUMENT RECORD CARD AUDIT SUMMARY
                                                                               Drawing
    DRC/ Drawing #                             E&DCR #        N&D #           Station #   Discrepancy
    BZ-515K-1                                                                 143,31    missing summary
                                                              10934
                                               FJ40812
                                                              10722
    2170.430.565-138                                                          143,31    DRC not current @ 31
                                               FB39178                                  missing
                                               FB38808
                                               FB38480
    2170.430.565-144                                                          143,31    DRC not current @ 143;
                                                                                        2 missing summaries
                                               FB3043                                   missing
                                               FB40733
                                               FB39302
                                               FB38335
                                               FB37820
    2170.430.565-147                                                          143,31    DRC not current @ 31;
                                                                                        missing summary
                                                             10061
                                               FB39723
                                               FB39302
   LBZ-79C-1                                                                 62,31      3 missing summaries
                                                             10763
                                                             10777                         missing
                                                             10654
                                                             10705
                                                             10813
                                               FJ40581                                     missing
                                                             10656
                                                             10655
                                               FJ40568                                     missing
    BZ-79C-3                                                                 62,31      missing summary
   -BZ-79C-7                                                                 62,31      6 missing summaries
    BZ-79C-17                                                                62,31      5 missing summaries
    BZ-79C-77                                                                62,31      5 missing summaries
    BZ-79C-13                                                                62,31

'

   'BZ-79C-33                                                                62,31      7 missing summaries
                                                                 VII-12
      . _ _ - .    . _ _ _ _ _ _ _ _ _ - _                                                             .    . ..
                                                                                                                 ,
                                                       TABLE VII-1-(Continued)
                                                  DOCUMENT RECORD CARD AUDIT SUMMARY
                                                                                              ,
                                                                              Drawing
    DRC/ Drawing #                           E&DCR #         N&D #           Station #     Discrepancy
   BZ-79C-49                                                                 62,31
   BZ-79R                                                                    62,31     4 missing summaries
                                                            10311                           missing
                                                             10690                          missing
                                                            10692
                                                            10691
                                             FJ37525
                                             FJ36743
   BZ-79R-2                                                                 62,31
   BZ-79R-7                                                                 62,31
   BZ-79R-17                                                                62,31      4 missing summaries
  'BZ-828-1                                                                 62,31      DRC not current @ 62
                                                            11252                          missing
                                                            11136                          missing
                                                            10516
                                                            10027
                                                            10519
                                            -TJ-2078
                                                                                         *
                                           -TJ-2044
                                             FJ-34317
   BZ-82B-20                                                                62,31      missing summary
   EE-3AMX                                                                  12,31
                                             PE7099                                        missing
                                             TC1661
   EE-3QR                                                                   12,31
                                             FE40194
                                             DE233
  -EE-9A                                                                    138,31
   EE-9B                                                                    138,31
                                             TE397
                            '
   EE-9C                                                                    138.31
                                           1TE372
                                             FE21059
   EE-90                                                                    138,31
                                             FE34408.
                                           .TE372
                                                                V.li 3

L'

o, -

                                                                                             .
     ,                           TABLE VII-1 (Continued)
                            DOCUMENT' RECORD CARD AUDIT SUMMARY
                                                         Drawing                             '
        DRC/ Drawing #  E&DCR #        N&D #            Station #   Discrepancy
       .EE-9E                                           138,31
                        FC21059
                        FE20793
                                                                                             i
                                                                                             '
        EE-9AH.                                         138,31
                        PC134
                       lFE30057
                        FE29248
       ~EE-9AL                                          138,31                               '
                        FE21059

l FE20793

        EE-9R                                           138,31
                        FC21059
                        FE20793
                       JFE16126
        EE-9W                                           138,31    missing. summary           '
                        TE2347
                        TE1819
                        FE39660
                        FE38584
        EK-501001                                       138,31
        EK-501002                                       138,31-
        EK-501021shi                                    138,31
   .
        EK-501021sh2                                    138,31    DRC missing 9 138;
                                                                  DRC not current 9-31
        EK-501049.                                      138,31
        EK-501050                                      '138,31
        EK-501065'                                    .138,31
       5EK-501083                                       138,31
 ,
        EK-501084                                     .138,31                                ,
        EK-501136                                       138,31
        EK-501137                                       138,31-
                                          VII-14
                                                                                 .. .- . - .

.,

_
                                      TABLE VII-1 (Continued)
                                 DOCUMENT RECORD CARD AUDIT SUMMARY
                                                             Drawing
           DRC/ Drawing #    E&DCR #.       N&D #           Station #   Discrepancy
           EP-17G                                           34,31     drawing missing @ 34
                            .PP7188
                             FP36330                                     missing
                             FP35795
           EP-71A                                           34,31     drawing missing @ 34
                                            9736
                             FS38804
                                            4700                         missing
    -
           EP-72G                                          34,31      drawing missing @ 34
                             PR6335       .
                             PR6221
                            'PP5420
          EP-72J                                           34,31      drawing missing @ 34
          EP-72T                                           34,31      2 missing summaries
                             FP35921
                                            8191
                             FP37554                                     missing
         - EP-74P                                          34,31
                             TP2830-                                     missing-
                             TP2334
                             FP38340-
        -
          EPL109C                                          34,31
                             FP31059.                                    missing
                             PP5986                                      missing
                          ,
      v
  $
                                               VII-15
                                       TABLE VII-2
                               SPECIFICATION AUDIT SUMMARY
    Specification #.   Subject                   E&DCR #   N&D # Discrepancy
,
  L2412.100-247        Electrical Penetrations                   spec missing from
                                                                  control point
                                                 FE34301
                                                 FE36450
                                                 FC37909         posting error (NA to
                                                                  this spec)
                                                 FE39071
                                                 FE36284         posting error, (not
                                                                   listed on spec
                                                                  Document Control Log)
    2400.000-350      Electrical Installation
                                                 FE41022
                                                 FE40990
                                                 TE3090
  - 2472.210-377      D/P Indicators &
                         Switches
                                                 TC645
                                                 TC693
                                                 FE33550
                                                                                        '
  - 2190.371-442      Metal Siding and
                        Roof Decking
                                                 PS-4198
                                                 PS-5959
                                                 PS-6885
                                                 PS-7247
   2170.430-565       HVAC Installation
                                                          10439
                                                           10426
                                                          10023
   2472.310-683       RTD & Thermowells          PQ5416
                                                 PC5929
  12282.150-713       2" valves                  PP5925
                                                 PP7333
                                                A235

'

   2200.000-914      . Mech. Equip. Erection                     latest spec rev'not
                                                                  filed; latest E&DCRs
                                                                  not filed
                                         VII-16
L

,w

                              TABLE VII-2.(Continued)
                           SPECIFICATION AUDIT SUMMARY
  -Specification # Subject                   E&DCR #  N&D # Discrepancy
  -2472.800-943    Instrusentation
                    Installation
                                             FC40336
                                            FC40337
                                            FC40983
                                            TC2414
                                            TC2750
   2280.000-968    Ppg Fab & Erection                       E&DCRs not filed
                                                             properly (at one
                                                             control point)
                                                            latest spec rev and
                                                             addenda not filed;
                                                            latest E&DCRs not
                                                             filed (at another
                                                             control point)
                                                            Engineering Spec Index
                                                             did not show latest
                                                             spec addenda

l

                                     VII-17
                                    *

F.: ,

        -
                              s
                                             -TABLE VII-3
                                          OIM AUDIT SUMMARY'
                                                                 ,
    '
                     -0IM #         Subject                      Discrepancy-
           .
                 ' 109-001A.-    Personnel Air Lock
                 1140-001A       Axial Flow-Fans             All E&DCRs were noti
                                                             posted in CDC' log
                   154-003A-    - 1500 lb valves
                   162-1A-       MS Safety. Valves
                  '177-1A        MS Isolation. Trip Valve
                  -190-2A-       Orifice Plates
                 ~ 241-001A      Emergency Diesel Gen.       EDC 0IM Index did not-
                                                             show latest rev; all'
                                                             E&DCRs were not posted
                                                             in CDC log; 1S-305-
                                                             data entry errors
                   244-001A      Motor Control Center.
                 - 261-001A      Static Inverter
                  :263-001A-     AC Dist. Panels-
                 1943-001A-      CPI Tube Fitting-
      ,
                   943-25B       Photohelic. Press. Sw
             -
        f
         -
                                               VII-18
               '
  .c

L. ;

  VIII. CORRECTIVE ACTION SYSTEMS
          A. Objective
             The corrective action systems and related activities were examined to
             determine whether measures were established and implemented to assure
             that nonconformances and other conditions adverse to quality were
             promptly identified and corrected.
          B. Discussion
             An examination was made of the licensee's program for identification and
             control of corrective actions, including review of sample documents and
             inspection of some material / equipment for verification of actual cor-
             rective actions in the plant. Items such as the following were

!

             reviewed:
                  Procedures and organizational interfaces
             *
                 . Trending
                  Audits and surveillances
             *
                  Measures for identification and resolution of nonconformances
             *
                  Measures to prevent recurrence
                  Control of equipment qualification nonconformances
                  Tracking of nonconformances
                  Stop work process
                 . Control of actual material and equipment corrections in the plant
                  Control of open nonconformances at turnover for testing or operation
             The following procedures by Stone & Webster Engineering Corporation
             (SWEC), Northeast Utilities Service Company (NUSCO) and Northeast
             Nuclear Energy Company (NNECO) related to corrective action systems
             were reviewed:
                  SWEC " Quality Assurance Program Manual," Rev. H
                  NUSCO " Northeast Utilities Quality Assurance Program Topical

l_ Report," Rev. 6

             *
                  NUSC0/NNECO Nuclear Engineering and Operations Procedure (NE0)
                  2.11, " Trend Analysis From Quality-Related Documents," Rev. 1
                  SWEC Project-Test Program Directive (PTPD)
                  5.1, " Control of Nonconformances at Turnover," Rev. 3, Change No. 2
                                            VIII-1
             .                  . - _       -       .        _       _     ._ _     - _.             ._    __.   -_ _. _. .   .

,

                   -
 4
                     '
                                        *-
                                                SWEC Quality Standards-(QS):
                                                                                                                                3
            ~
                                                2.3; Rev.LA, Stop_ Work Action
                                                14.2,' Rev. F, Inspection' Report System
                                                               ~
                                               '15.1, Rev._B, Nonconformance & Disposition Report, Change No. 1
     ~
                                                15.3, Rev. C, Risk Release of UNSAT/ Nonconforming                              i
    -
                                                     Material / Equipment:
                                                16.1,-Rev.-B, SWEC: Problem. Reporting System
                                              ;16.2,. Rev. , Notifying . Clients of Potential- 55(e)
                                              116.3, Rev. A, Identifying and Reporting 10 CFR 21
                                                18.1',1Rev.~B,- Quality Audit Program
                                                14.1 ML, Rev. B, Post-Acceptance Work Control
                                        *
                                                SWEC Quality Assurance Directives (QAD):
                                                14.1, Rev. D, Inspection Report System-

t

   s                                           '18.1,~ Rev. C,. Quality Assurance Audit System
                                          .
                                               118.'2,    Rev. C,-Quality Audit plan
                                                18.11, Rev. F, QA Program Audits of Sellers                                 s   ,
                                        *                                                  ~
                                                SWEC, Quality'Contro1' Instructions (QCI):
         %
                                              -FM3-514.2-06, Rev. A, Site QA Program Monitoring
                                                FM3-S14.2-07, Rev.'C, ASME N-5 Inspections
                                        *-
                                                SWEC Northeast Administrative Manual (NEAM):

-

    :
     *
                       .                      .31, Rev.:7, Handling of Problem Reports, Reports of. Problems and              -)
                                                  ' Initial Problem Reports
                                                  -
                                                68,'Rev. 5, Handling of,Nonconformance and Disposition Reports,-
                                                     Change No. 3
                                                114, Rev. 1, Reportable.0ccurences Reports,- 10 CFR 50.55(e) and-
                                                     10 CFR 21-                                                                -
                                      ~* '
                                                SWEC Field Construction ~ Procedures (FCP):
                                                292, Rev. 1,: Disassembly / Reassembly of Components / Equipment
                                                335, Rev.'2, Trend Analysis and Corrective Action Committee
    '             '
                                                337, Rev.' 3, Preparing-Stress Reconciliation Piping Location-
                                                                                '
                                                      Isometrics (PLIs)
       '             ~
                                   '
               '
                                      -*
                           '
                                                SWEC-Quality Assurance and. Control Manual,~ASME-Section III,
                                                Division 1
                                                                 '
                                                                                                                                ;

'

                                              lSection 15, Rev. J, Nonconformances
                                                                                                                                '
                                        1.      Corrective Action Measures

L ' a. ' Inspection Scope -

                 '

o

                                                A review was performed of applicable portions of~the QA program and
                                                procedures. A total of 263 corrective action documents were
                                                reviewed and 10 material / equipment samples were inspected for

, '

                                               ' verification of corrective actions in the plant. _Also, three
       -
                                               -samples of risk releases were selected for-field verification of

L

           -             -
                             - +-                                                 _

L L n

 __
         control and status of work on material / equipment to correct the
        deficient condition involved. Table VIII-1, " Corrective Action
        Samples," contains a summary list of documents and material /.
        equipment samples that were randomly selected and inspected.
    b.   Inspection Findings
         In general, it was found that satisfactory procedures were in place
        for corrective action systems to identify and correct conditions
        adverse to quality at the site. _ Generally, except for concerns
        discussed-below, the corrective action measures were found to be
        acceptable. The 10 material / equipment samples requiring rework in
        the plant were inspected and corrective action was verified. The
       .three samples of risk releases were inspected and found to be
        properly controlled. However, the following observations were made
       .by the NRC CAT inspector:
        (1) Nonconformance and Disposition Reports (N&Ds) and UNSAT
             ' Inspection Reports (irs) did not document actions or need for
              actions to prevent recurrence of nonconformances. SWEC
              representatives stated that, while no provision was made on
              N&D and IR forms to document action to prevent recurrence,
              such actions were provided by other means.    It was stated that
              the trending activities of the project required a review of
              programmatic Type C irs, N&Ds and UNSAT Type A irs to identify _
              nonconformances and negative treeds, and that the results of
              such reviews would bring about action to prevent significant
              recurrences. Also, SWEC representatives stated that the
              practices at the site included action by discipline quality
              control (QC) inspectors as well as construction supervisors, to
              promptly notify responsible parties by interoffice correspond-
              ence,-memorandums, or verbally to expedite review / action to
              avoid recurrence of significant N&Ds and UNSAT irs.
              This response was of concern to the NRC CAT inspector because
              of these informal practices and delays in the trending program
              to bring about action to avoid recurrence of significent
              nonconformances.
              This matter requires additional management attention to assure
              that nonconformances requiring action to prevent recurrence are
              promptly identified and appropriate action is taken.
        (2) NUSCO Construction Quality Assurance (CQA) Audit No. A-40958
              (conducted 7/9/84-11/28/84) of preventive maintenance and
              in place equipment storage documented findings regarding
              improper preventive maintenance of mechanical and electrical
              equipment. However, follow-up responses did not address the
              damage that may have been caused due to improper maintenance.
             Also, the NRC CAT inspectors found deficiencies (without correc-
              tive action) in preventive maintenance of various mechanical
              and electrical equipments. Refer to Section III.B.S.b for
             details regarding mechanical equipment, and Section II.B.3.b(1)

L for details regarding electrical equipment. '

                                   VIII-3

L

  C. ;
           ^<
           e.-
                 - -
           - .
                   . ,
              "
                                         (3) Review of. Deficiency and Construction Work Permit (CWP).
                                              . Reports by NNEC0 revealed an. increasing magnitude of open
                                             . N&Ds, UNSAT. irs,f and other deficiencies.                           <
   b                                            A1 total _of'9,051.open items for approximately 200 system
                                             ; packages.(of a total of 245) already turned.over to NNECO was
                                                noted as of March 21,:1985. - Also, the Master Deficiency List
                                               . included in Deficiency _and CWP Report as of March 26, 1985~
                                                showed an increase of open items for six reporting periods,
       -
                                                from 8,369 as'of January 30, 1985 to 9,021 as of March 16,
                                                1985.
                                                The concern is the increasing magnitude of open deficiencies-
                                                to be resolvediafter-turnover to NNECO, with rework activities
                                                proceeding under different' controls and conditions,.may. result
                                                in decreased contro1~of. quality of such work to complete the
                                                plant.
                                               This matter requires special management attention.
   '
                   -
                                      -(4) Review of design. change control activities at the site revealed
         2
                                               deficiencies for which effective corrective actions were not :
     ,                   _                     performed. .The followin'g.is a list of some such deficiencies:
                                               *
                                                      Incorrect information printed on back of document record.
                                                                                                         ~
                                                      cards (DRCs).   (Refer to Section VII.B.1.b.(3) for details.)
                                               *'
         -
                     ,
                           ~                          Numerous recurring document control. problems at site

'

                                                    : drawing stations. (Refer to Section VII.B.1.b.(7) for

>

                                                     . details.).

i

                                               *
        ,                                           . Increasing number of design documents overdue for updating.
                                                      (Refer to Section VII.B.2.b.(2) for details.)
                                              '"
                                                      Improved procedure for relating engineering and design
                                                     change requests.(E&DCRs) to originating project change

r ,

                                                    -requests (PCRs) was not. implemented. (Refer to Section

't -_VII.B.2.b.(3) for details.'):

                               - c .' Conclusions

Y -Weaknesses in the licensee's corrective action program were.found

                                       in the following areas:
                       '
     .
                                       *

'

                                        '
                                             ' Failure to promptly document the need for action to avoid
               -                               recurrence of nonconformances.

"

                                       *
                             -
                                             ' Lack of control of preventive maintenance and corrective action-

< '

                                               for def.icient. preventive maintenance after turnover for
                                               testing / operation.
                                       *

l The increasing magnitude of nonconformances at turnover for .

                                       ,
                                               testing / operation.
                                       *
                                               Failure to apply effective corrective actions for design change

. -control and document control deficiencies. <

                                                                      VIII-4
 <
       -
           n   =
         + -
 -
                                                      TABLE VIII-1
                                                CORRECTIVE ACTION SAMPLES
                                       ITEM :'                            QUANTITY EXAMINED
                 .'(1) Construction-Quality Assurance (CQA)-                     6
                          ~ Audit (NUSCO)-
                            -
                 -(2):?In' Process, Verification Report (IPV) (NUSCO)            5
                 T(3)J Surveillance Report'(NUSCO)
                                          -                                    24
                  (4) Significant Deficiencies (SDs) (NUSCO)                     4
                  (5)..QA Site Audit Report (SWEC-Corp.)
                                                    -
                                                                                 3
   ,
                 L(6) Audit of Contractor (SWEC-PQA)                             1
                 :(7) ~N&D' Corrective' Action Committee Report                  3
                              (Including N&D Trend Report) (SWEC)
                 -(8) QA Department Monthly Project Report (SWEC-FQC)            5
                  (9)- Monthly QA Progress. Meeting Report (SWEC)                3
                 -(10) Stop Work Directive (SWEC)                                2
                  (11) Report of a Problem (ROAP) (SWEC)
                                                  -
                                                                                 4
                  ~(12) Inspe'ction Report -Type C (SWEC)                     '53              *
                                                ~
                  (13) Inspection Report - Type A UNSAT (SWEC):
                        * Mechanical                                           10
                        * Piping                                               15
                        * HVAC                                                   5
                        * Electrical                                          -20

s -- * Instrumentation 15 i

                        * Structural
                          --                                                    'S-
                 .(14) Nonconformance and Disposition Report (N&D) (SWEC):
                        * Mechanical-                                            8
                        * Piping'                                              10
             ,          * Welding                                                9
                        * HVAC                                                   6
                        * Electrical                                           12'          --
                       L* Instrumentation-                                       5
                        * Structural                                             3
                        *~ Preventive. Maintenance                               6
                  ~(15) Risk Release (SWEC)                                    16
                                                                                       .
                   ~
                                                        .'VIII-5
     ,
                            TABLE:VIII-1 (Continued)
                            CORRECTIVE ACTION SAMPLES
                  ITEM                                     QUANTITY EXAMINED
      (16) Installation Completion Report (SWEC)-                     2
     . (17) Deficiency and Construction Work Permit                   2
               (CWP) Report NNECO
                                            SUB-TOTAL DOCUMENTS     263
      (18) Material / Equipment Samples for Field                    10
              Verificatico of Corrective Action
      (19) Risk Release Samples for-Field Verification of             3
              Control'of Corrective Action
                                                 TOTAL SAMPLES      276
              ,
   9

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                                    VIII-6
                  ,.                     .     _         ._      . - . _ .  .        _             ._                     _-
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       -
                                                                           o                                  .
                                                                                              ATTACHMENT-A

u , <

   1<         A.       PERSONS CONTACTED

L The 'following ' list identifies licensee representatives and NRC personnel '

                      .present atithe exit meeting, licensee discipline coordinators for each
                     - area, Land individuals' contacted during the inspection.
                       1.         Exit meeting
                                 Licensee
                                11. Albee              R. Lefebvre             G. Pittman
                                 G. Baston             D. Miller               P.-Quinlan
                                  R. Busch             E. Mroczha              F.-Rothen
                                 J. Crockett           L. Nadeau              .W. Rotherforhh
                                -J. Ferland            D. Nordquist            C. Schaffer
                                                                               A. Silva
   ~
                               .M. Hess                S. Orcfice_
                                  R. Josh              V. Papadopoli.          R. Werner
                                -Stone and Webster Engineering Corporation
                                  R. Ackley            G. Milley.              R. Scannell
                               .W..Curtiss-            L. Nace                 C. Sprouse
                                 W. Emerson
                                                 "'
                                                        R. Plant               G. Turner

f

                   '
                                  R. Kelly             R.. Rudis-
                                                      ,
                               LNRC and Consultants
                                 -T. Chan'              E. McCabe              A. Saunders -
                                  R. Compton.          J. McCormack           .R. Serb
                                'E..Doolittle          J. Partlow .            W. Sperko
                                  D. Ford              H. Phillips:            R. Starostecki
                               .R. Heishman            T. Rebelowski           E. Wenzinger

a 0. Mallon S. Reynolds

                                                            .
                                                                               R. Wheeler.
                     1           W. Marini             R. Rohrbacher           H. Wong
                                  E. MartindaleL
                       2.         Licensee's Coordinators and Contacts
                                        Area                                      Name
                                                                                                                             ,
                               ' CAT Coordinator-                              L. Nadeau
                                                                               W. Curtiss
                        -
                            ' = Electrical. and- Instrumentation               R. Clark

J4! < D. Evans i.. P. Hogan ,

                          '^-
                                                                               R. Dietsel
                                  Mechanical                                   R.L Avery
                                                                               C. Clement
                                                                               R. Hagerman

,

                                                                               L. Peterson

i G. Wilson [

                 ,                                             AA-1
                                                                                                                             '

(-' . E _ . _ . _ . . - _ _ _

                  .We_lding and NDE                       'L. Peterson
                                                           W. Taylor
                                                          - N. Hamer
                   Civil and Structural                    R. Zawacki
                                                           A. Morales
                 ~ Material _ Traceability'                A. Little
                   Design Change Control                   R. Rudis'
                 ~ Corrective Action Systems               W.' Vos
             In addition to the above personnel, numerous other inspectors, engineers,
             and supervisory personnel were'also contacted.
       .
                                                 .
         4
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d 4 .

    ;-
           ~
                                             AA-2
 L_-
-
      ~
               B. ' Documents' Reviewed
                    The' types'of documents listed below were revi.ewed by the NRC CAT
                    members ~to the extent necessary to satisfy the. inspection objectives
                  -stated in Section I of this report.       References to specific procedures,-
                  ; specifications,-and drawings are contained within the body of the report.
                    : 1.    Final Safety Analysis Report
                      2.    Quality assurance manuals
                     -3. ~ Quality assurance procedures
  ,
                      4.1 Quality' control procedures
                      5.    Administrative procedures
                     16. General electrical construction procedures and specifications-
                      7.-   General instrumentation construction procedures and specifications
             -
                    9 8.' ' General! piping and' pipe support installation procedures and
                           -specifications
                      9.    General _ mechanical equipment installation procedures and
                           . specifications.
                    10. 2 General concrete specifications
                  .11. _As-built drawings
                    12. Welding and NDE procedures
    ,
                  ~13.      Personnel q'ualification records
          
                  l14.~ Material traceability procedures
                    15.     Procedures for processing design changes
                    16.     Procedures for document control-
                  - 17.     Procedures for controlling as-built drawings
                    18 _ Procedures for_ processing nonconformances
        -

'

                                                        AA-3
                                                            ATTACHMENT B
                              ' GLOSSARY OF ABBREVIATIONS
 AISC       American Institute of Steel Construction, Inc.
 ANNULUS.   Containment Building Annulus
 ANSI       American National Standards Institute
 ATWS       Anticipated Transient Without Scram
 ASME       American Society of Mechanical Engineers
 ASTM       American Society of Testing & Materials
 AUX       Auxiliary Building
 AWG        American Wire Gage
 AWS       American Welding Society
 BLK        Black
 BLU        Blue
 CAT        Construction Appraisal Team (NRC)
 CFR        Code of Federal Regulations
 CMP      . Construction Methods Procedure
 CMTR      Certified Material Test Report
 C of C     Certificate of Compliance
 CONT-    . Containment Building
 CQA       Construction Quality Assurance
 CTI       Construction Team Inspection
 CWP       Construction Work Permit
 DRC       Document Record Card-
 EA         Engineering Assurance
 EAP       Engineering Assurance Procedure
 E&DCR     Engineering and Design Coordination Report
 ESF       Engineering Safety Features Building
 ESS0W     Engineering Service Scope.of Work
 FCN       Field Change Notice
 FPC       Field Construction Procedures
 FQC       Field Quality Control
 FSAR      Final Safety Analysis Report
 GRN       Green
 GTAW      Gas Tungsten Arc Welding
 HVAC      Heating, Ventilating and Air Conditioning
 ICEA      Insulated Cable Engineers Association
 IE        Office of Inspection and Enforcement (NRC)
 IEEE      Institute of Electrical and Electronic Engineers
 IR        Inspection Report
 IS        Information System
 LIW       Load Indicating Washers
 MCB.      Main Control Board
 MCC .     Motor Control Center
 MSVB      Main Steam Valve Building
 N&D       Nonconformance and Disposition Report
 NDE       Nondestructive Examination
 NEAM      Northeast Administrative Manual
 NETM      Northeast Technical Manual
 NE0       Nuclear Engineering and Operations Procedure
 NNECO     Northeast Nuclear Energy Company
                                         AB-1

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                                                          ATTACHMENT B
                    GLOSSARY OF ABBREVIATIONS (Continued)
 NRC     Nuclear Regulatory Commission
 NRR     Office of Nuclear Reactor Regulation (NRC)
 NSSS    Nuclear Steam Supply System
 NUSCO   Northeast Utilities Service Company
 NUQAP   Northeast Utilities Quality Assurance Program
 NVEC0   Northeast Ventilation Company
 OIM     Operating, Installation and Maintenance Manual
 ORG     Orange
 PCR     Project Change Request
 PLI     Piping Location Isometric
 PTPD    Project Test Program Directive
 PWHT    Post Weld Heat Treatment
 QA     Quality Assurance
 QAAD   Quality Assurance Auditing Division
 QAD    Quality Assurance Directives
 QC     Quality Control
 QCI    Quality Control Instruction
 QS     Quality Standards
 RG-     Regulatory Guide (NRC)
 ROAP    Report of a Problem
 RPS     Reactor Protection System
 SAE     Society of Automotive Engineers
 SAR    Safety Analysis Report
 SEG    SWEC Site Engineering Group
 SIH    High Pressure Safety Injection
 SMA    Shielded Metal Arc
 SMAW   Shielded Metal Arc Welding
 SWEC'  Stone and Webster Engineering Corporation
 TR     Trouble Report
 TVS    Thames Valley Steel-Corporation
 UNSAT -Unsatisfactory
 UT     Ultrasonic Test
 VIR    Vendor Information Request
 WHT.   White
 WPS-  . Weld Procedure Specification
                                      AB-2

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                                                                                      ,
 NRC Form 8-C
     (4-79)
   NRCM 0240
                          COVER SHEET FOR CORRESPONDENCE

! Use this Cover Sheet to Protect Originals of Multi-Page Correspondence.

                                                                                      i

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