IR 05000498/1985021

Const Appraisal Team Insp Repts 50-498/85-21 & 50-499/85-19 on 851021-1101 & 12-22.Potential Enforcement Action Noted: Failure to Provide Adequate Interface Between Design Organizations (A/E) & NSSS

ML20151V035
Person / Time
Site:	South Texas
Issue date:	01/17/1986
From:	Garrison D, Georgiev G, Heishman R, Mclellan T, Nemoto J, Peranich M, Phillips H, Phillips H, Stein S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20151V027	List: ML20151V023 ML20151V035
References
50-498-85-21, 50-499-85-19, NUDOCS 8602110181
Download: ML20151V035 (200)

Text

UNITED STATES NUCLEAR REGULATORY COMISSION OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF INSPECTION PROGRAMS REACTOR CONSTRUCTION PROGRAMS BRANCH Report No.: 50-498/85-21,499/85-19 Docket No.: 50-498, 50-499 Licensee: Houston Lighting and Power Company Facility Name: South Texas Project Inspection At: Matagorda County, Texas Inspection Conducted: October 21-November 1 and November 12-22, 1985 Inspectors: / M '#

M. W. Peranich, Chief Construction Programs /

/////74 Date 51gned CAT Section, Team Leader W hr /

'Inspedtor h (Region IV)

Y'/fC D&te' Signed

<D.L.Garytson,feside N. /\lm LE& /f/0 86

)rgiev, Sr. Retctor Co truction Engineer Date S4gned

/G.B.Ge I r Y Y?Yk T. K. McLellan, Reactor Construction Engineer

///r/d4 D4te' Signed L ll ///O/86 gmoto, Reac Construction Engineer Ddte S'igned

& M 2 . kto M. W. P ipips, Reactor struction Engineer egu Date Signed

. ' {&J.'Jn -

'

~^

' S. R. Stein, Riactor Construction Engineer

/ ok6 Date Signed Consultants: S. L. Baron, A. V. duBouchet, D. C. Ford, J. B. McCormack, O. P. Mallon, E. Y. Martindale W. J. Sperko, Jr. , D. G. Whatley,

/,

Approved By: / _

Robert F. Heishman, Chief 0(te' Signed Reactor Construction Programs Branch 0602110101 06020S ,-

• R. !!. Compton was inadvertently omitted PDR ADOCK 0500 0 from the list of consultant O

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

_ _ _ _ _ _ _ _ _ _ _ _ _ _

TABLE OF CONTENTS TOPIC SECTION INSPECTION SCOPE AND OBJECTIVES............................... I ELECTRICAL AND INSTRUMENTATION CONSTRUCTION................... II MECHANICAL CONSTRUCTION....................................... III WELDING AND NONDESTRUCTIVE EXAMINATION........................ IV CIVIL AND STRUCTURAL CONSTRUCTION............................. V MATERIAL TRACEABILITY AND CONTR0L............................. VI DESIGN CHANGE CONTR0L......................................... VII CORRECTIVE ACTION SYSTEMS..................................... VIII ATTACHMENT A - PERSONS CONTACTED AND DOCUMENTS REVIEWED ATTACHMENT B - GLOSSARY OF ABBREVIATIONS l

I

_ _ _ . _ _ _ . _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

. _ _ _ . _ _ . _ ._ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ INSPECTION SCOPE AND OBJECTIVES The objective of this inspection was to evaluate the adequacy of construction at the South Texas Project site. This objective was accomplished through review of the construction program, evaluation nf  ;

project construction controls, and review of selected portions of the i Quality Assurance Program, with emphasis on the installed hardware in the i field. The scope and significance of identified problems were also i determine '

F Within the areas examined, the inspection consisted of a detailed examination of selected hardware subsequent to quality control inspections, a selective examination of procedures and representative records, and limited observation of in process wor For each of the areas inspected, the following was determined: )

Were project construction controls adequate to assure quality i construction?

Was the hardware or product fabricated or installed as designed?

r

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

,

&

r (

,

i

1-1

_ _____ __-__- - _ _ - - _ _ _ _ _ _ - - - - - _ _ _ - - _ _ _ _

W II. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION i Objective The primary objective of the appraisal of electrical and instrumentation construction was to determine whether safety-related components and systems were installed in accordance with regulatory

. requirements, Safety Analysis Report commitments, and approved vendor and construction specifications 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 wor Discussion Within the broad categories of electrical and instrumentation construction, attention was given to several specific areas. These included electrical cable, raceways and raceway supports, electrical equipment, and instrumentation tubing and components. Additionally, a review as made of a selected number of documents associated with design change control and nonconformance reportin A number of documents were generated by the applicant to record individual observations of the NRC Construction Appraisal Team (CAT)

inspectors, and are referenced directly in the discussions that follo . Electrical Raceway Installation Inspection Scope Seventy-two segments of installed Class 1E cable tray, representing a total length of about 1,000 feet, were selected from various plant areas for detailed examination by the NRC CAT. These segments were inspected for compliance to requirements relative to routing, location, separation, support spacing and configuration, identification, protection, and physical loading. Additionally, 28 runs of installed conduit, with an aggregate length of about 1,600 feet, were inspected for compliance to specified requirements such as routing, location, separation, bend radii, support spacing, and associated fitting Twenty-eight raceway supports were examined in detail for such items as location, material, anchor spacing, weld quality, bolt torque, and installed configuratio See Table 11-1 for a listing of cable tray, conduit, and raceway support sample The following documents provided the basic acceptance criteria for the inspection:

Bechtel Specification 3E189ES1000, " Conduit and Tray Supports,"

Rev. 6 11-1

-

___ __________-____-___ _ _ _ _ _ _

Ebasco Quality Control Procedure (QCP) 10.16, " Inspection of Electrical Raceways," Rev. 4

Ebasco QCP-10.30, " Inspection of Installation and Fabrication of Electrical Cable Tray Hangers, Conduit Supports and Auxiliary Steel," Rev. 1

Ebasco Construction Site Procedure (CSP) 40, "EE580 Electrical Installation," Rev. 4 b. Inspection Findings In the area of electrical raceway the NRC CAT inspectors observed that, in general, Class 1E raceway installations were in accordance with applicable design criteria. Quality attributes such as material type, location, identification, and installed configuration were found to be as shown on approved construction drawing However, several deficiencies in design or construction or both were identified and are discussed belo (1) Raceway Separation

The South Texas Project (STP) Final Safety Analysis Report l (FSAR) section 8.3.1.4, entitled " Separation of Redundant

'

Systems," provides the basic criteria for acceptable Class 1E circuit and electrical raceway installations. This FSAR section describes commitments for physical arrangement of raceways which pertain to the requirements of Regulatory Guide (RG) 1.75 for independence of redundant systems. In general, these FSAR criteria specify the physical separation which must be maintained between components of redundant electrical division Additionally, physical separation is required between components performing Class 1E and non-Class 1E function During the examination of the selected raceway sample, NRC CAT inspectors observed that a number of installations were not in accordance with the FSAR requirement Deficiencies were identified in several areas of the plant but were most common in the Mechanical / Electrical Auxiliary building. In this area

'

numerous Class 1E raceway components had been installed without the required physical separation. See Table Il-2 for a listing of the identified raceway segments that violated separation criteri NRC CAT inspectors discussed this issue with licensee personnel and reviewed relevant inspection procedures, design drawings and plant historical records to determine why those deficien-cies exist. The review indicates that the licensee had identified problems in the area of electrical separation as

'

early as 198 Corrective Action Report (CAR) G-434, dated May 8, 1984, details specific violations of relevant FSAR l criteri Additionally, other site initiated documents such l as the " Final Report for STP Pre-CAT Verification," dated July j 18, 1985, highlight deficiencies in this area.

Il-2

_ _ _ _ - _ _ _ _

In reviewing these documents NRC CAT inspectors expressed i

concerns with regard to actions taken to correct existing deficiencies. As an example, in response to the deficiencies identified in CAR G-434 the licensee elected to postpone the inspaction of raceway division separation until the time of area turnove Relevant inspection and construction procedures were then revised to reflect this decision by eliminating the attribute of division separation from inspection of cable tray and conduit. Discussions with licensee personnel indicate that

>

this decision was made based upon the fact that construction activities are ongoing and thus it is not prudent to identify separation violations prior to completion of any given are At the time of area turnover, a walkdown of each area is planned by Ebasco engineering to identify violations in separation and determine the course of action necessary to alleviate those problems. Additionally, Ebasco Quality Control (QC) personnel will perform an inspection after the installation of required barriers in accordance with the applicable Quality Control Procedur NRC CAT inspectors noted that many of the deficiencies identi-fled during the examination of the raceway sample involved i components which were part of a system turned over to Houston

!

Lighting and Power Company (HL&P) Startu Consequently, component modification or installation of barriers which may result from future inspection activities may adversely affect plant systems which have been turned over and accepte Several aspects of the licensee's proposed inspection and engineering walkdown programs were evaluated, including a review of Standard Site Procedure SSP-45. This procedure, issued on October 25, 1985 during the NRC CAT inspection, provides the basic acceptance criteria which will be used for future inspection of separation between electrical component The procedure content appears thorough, but because inspection activity has not commenced an evaluation of program effec-tiveness could not be mad In summary, while it is clear that the licensee is aware of existing separation deficiencies, the implementation and effectiveness of actions planned to correct these and other currently unidentified deficiencies requires further evalua-tio NRC CAT inspectors also observed several raceway installations in which redundant divisional cable tray or conduit had been attached to a common raceway support. NRC CAT inspectors expressed concern that this configuration does not meet the intent of RG 1.75 position C.3 which states that "In general, locating redundant circuits and equipment in separate safety class structures affords a greater degree of assurance that a

'

single event will not affect redundant systems. This method of separation should be used whenever practicable and where its use does not conflict with other safety objectives."

!!-3

. _ _ _ _ _ _ __-_-____ ______- ___ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

This concern,.and its relationship to plant missile protec-tion, was discussed with licensee personnel. With regard to the common support of redundant raceways, it.is postulated that a single event (i.e., missile impact) could adversely affect the function of redundant divisional circuit NRC CAT inspectors reviewed section 3.5 of the STP FSAR. This section and its Table 3.5-1 contain criteria for missile protection for South Texas Project. Specific attention was given to the FSAR discussion under the heading Internally Generated Missiles Outside of Containment, ar.d the protective measures required by the referenced table. NRC CAT inspectors also reviewed Bechtel Project Engineering Directive PED-039 entitled " Engineering Evaluation Walkdowns" and the Systems Interaction Design Guide PED-016 entitled " Internally Generated Missiles."

One area of concern was identified during this review and was discussed with licensee personnel. FSAR Table 3.5-1 describes safety class systems and components and seismic category I structures which require missile protection. The table appears to provide exclusions for the categories of cable raceway l systems and electrical supports based on component redundancy.

i However. as previously discussed the NRC CAT inspectors noted I

that redundant raceway installations that are attached to a common support would be equally affected by missile impac As a result of this observation the licensee has issued FSAR l Change Notice 779 to more appropriately reflect the intent of

!

Table 3.5-1 to include raceways and raceway supports in missile protection evaluations. This resolves the NRC CAT concern in this are (2) Electrical Conduit

'

With exception of the specific deficiencies listed below, the conduit sample inspected conformed to applicable design and installation requirements relative to such attributes as size, routing, identification and proper supports.

l Conduit C1XM3ER5204'was found to have a support distance violation between two supports, and conduit AIXE2ARY102 was not identified with its safety division marking at the required 15 i feet intervals. These two isolated deficiencies were sub- ,

sequently recorded on Nonconformance Reports (NCRs) CE-03207

'

l and CE-03213 by the license The strap bolts for eight QC accepted conduits did not exihibit l

torque seal as required by project instructions. QCP-10.30 requires QC to verify the torque on at least one bolt from each connection and requires the verified bolt to be marked with

! torque seal. Discussion with the licensee indicates that the l lack of or partial application of torque seal for QC accepted l conduits is due to removal and reinstallation without reinspec-l tion by QC. NRC CAT inspectors concluded that the licensee's l ccentrol of QC accepted conduit installation is not completely II-4 l

effectiv The inadequate torque sealing was subsequently recorded on NCR CE-03213 by the license (3) Raceway Supports The examination of raceway supports included conduit and cable tray supports. Attributes such as location, material type and size, anchor spacing and embedded length, welds (location, size and general quality), and installed configuration were found to be in accordance with design requirements. However, several isolated hardware deficiencies and one documentation deficiency were identified.'

It was noted by the NRC CAT inspectors that the traveler package for cable tray hanger 2-002-H3 included the inspection report for a different hanger. The licensee's subsequent investigation revealed a number of documentation errors and omissions attributable to hangers inspected by the same QC inspector. The licensee has issued Standard Deficiency Reports (SDRs) E-361 and E-362 to document and correct these deficiencie The torque of approximately 150 bolts and 50 concrete anchors of various sizes on raceway supports was verified by the NRC CAT inspectors. Three cable tray supports, 2-103-H61, 1-010-H84 and 1-024-H52, each contained several 1/2-inch strut bolts which did not meet minimum torque requirements. These deficiencies were documented on NCRs CK-03111, and CE-0322 Independent of the bolt torque sample, hanger 1-065-H11 was also found to contain several loose 1/2-inch strut bolts even though the bolts were marked with torque seal. In addition, the embedded lengths of 17 concrete anchors were verified using an ultrasonic inspection method with no items of concern note It was noted by the NRC CAT inspectors that virtually all the 1/2-inch strut bolts had no markings on the bolt heads making identification of the material indeterminate. Beginning with Rev. 3 in 1983, Bechtel specification 3E189ES1000 requires these strut bolts to be from material conforming to American Society for Testing and Materials (ASTM) A-307, Grade B, but specifically negates the ASTM requirement for manufacturers'

markings. The use of ASTM A307 bolting materials without manufacturer's identification marks is also discussed in Section VI, Material Traceability and Control, of this repor Other than the indeterminate traceability of bolt material, the documentation and hardware discrepancies identified by the NRC CAT in this area are considered isolated cases, c. Conclusions

Except as noted, raceway systems have been installed in accordance l

'

with applicable design and installation requirements. However, numerous installations have not naintained the physical separation required by the licensee's commitment in the FSA In this area, it i

II-5 l

was determined that pertinent procedural.and administrative controls have only recently been developed. As such, the adequacy of electrical raceway separation after implementation of these controls at South Texas Project will require further evaluation by the licensee and NRC personne The number of reworked conduit installations that were found lacking QC reinspection of bolt torque indicate that rework of QC accepted conduit installations requires increased contro . Electrical Cable Installation a. Inspection Scope i The NRC CAT inspectors selected a sample of installed Class 1E cable runs that had been previously accepted by QC inspectors. The sample included medium and low voltage power, control, and instru-mentation cabling. 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 suppor Additionally, the NRC CAT inspectors selected approximately 108 l cable ends for examination of terminations. These were inspected to l applicable design and installation documents for items such as lug i size and type, proper terminal point configuration, correct identi-l fication of cable and conductors, proper crimping of lugs or

connectors, and absence of irmulation or jacket damag See Table l II-3 for a listing of cable terminations examine The following medium and low voltage power cable totaling about 1,700 feet were selected from different systems, electrical trains, and locations

Cable Type

'

AIDJAKC1LA 1/C No. 4 AWG B1CSABC1EA 1/C 250 MCM I

B1CHABC2LB 3/C No. 6 AWG BIRHADC1LE 3/C No. 10 AWG C1PKACC1GA 3-1/C 750 MCM D1VAABC1HB 3/C No. 4 AWG D1DJABC1LE 1/C 750 MCM The.following control cables totaling approximately 1,100 feet were selected from different systems, electrical trains, and locations:

Cable Type A1FWO7CISC 5/C No. 12 AWG A1JWO2C1SA 7/C No. 12 AWG C1PK01C3SK 3/C No. 16 AWG 01VA10C25A 7/C No. 12 AWG II-6

_ __ ____ _______-____ __ __

. _ _

The following instrument cable totaling approximately 1,000 feet were selected from different systems, electrical trains, and locations:

Cable Type AIDG04CIPA 2/C No. 16 Shielded AIDG04C1PC 2/C No. 16 Shielded A11114CAXF 2/C No. 16 Shielded BIRH03C2WD 2/C No. 16 Shielded D1VA10C2XA 2/C No. 16 Shielded D1DJ10C4XC 2/C No. 16 Shielded The following documents provided the basic acceptance criteria for the inspection:

• Bechtel Specification SE189ES1007, " Cable Installation In Trays, Conduits and Ductbanks," Rev. 5

• Bechtel Specification SE189ES1004, " Cable Splicing, Termination, and Supports," Rev. 5

• Bechtel Specification 5A230ES1008, " Installation of Electrical Cable, Raceway, and Equipment Identification," Rev. 6

• Ebasco QCP-10.17, " Electrical Cable Installation Inspection,"

Rev. 2

• Ebasco CSP-19, " Safety and Non-Safety-Related Cable Pulling,"

Rev. 4

• Ebasco CSP-8, " Cable Termination and Splices," Rev. I b. Inspection Findings (1) Routing In general, the routing of Class 1E cables through design designated raceway systems was found to be in accordance with specified criteria. Each of the Class 1E cables examined by NRC CAT inspectors had been installed in accordance with the routing detailed on the EE580 pull card The examination of Class 1E cables did disclose an apparent deficiency-in the routing of medium voltage cables into cable spreading areas. NRC CAT inspectors observed that these installations do not meet the requirements of IEEE 384-1974 section 5.1.3 which limits cable installation in a cable spreading room to circuits which perform control and instrumentation function Subsequent discussions with licensee personnel disclosed that the " cable spreading areas" were inaccurately defined on drawing SE-03-0E-0100 sheet 6AA Rev. O. Consequently, the medium voltage cables identified by NRC CAT inspectors were 11-7

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

.

e acceptably installed outside of actual cable spreading areas and were in accordance with IEEE-384 and RG 1.75. As a result of this observation the licensee has issued Design Change Notice (DCN) I to revi'se and clarify the referenced drawin (2) Separation In general, the separation of Class 1E cables was found to be in accordance with requirement NRC CAT inspectors did identify a number of Class 1E cable installations which exhibit inadequate separation at the entrance to Class 1E equipment. However, these deficiencies were the subject of Bechtel Deficiency Evaluation Report (DER)85-034 issued September 10, 1985, which was subsequently determined to be potentially reportable pursuant to 10 CFR 50.55(e). Evaluation of actions taken to correct existing deficiencies are in.accordance with this process and as such, NRC CAT inspectors have no additional observations in this are In~ general, the separation of Class 1E cables located inside of electrical equipment was found to conform with requirement One area where a deficiency was identified is in cubicle 3 of 4160V switchgear 3E151ESCOE1C. The physical separation between a non-Class 1E pull out~ fuse block and Class 1E wiring was less than the required six inches. As a result of this observation the licensee has issued NCR SE-03233 to identify and correct this conditio No other deficiencies were observed in this are (3) Power Cable Spacing and Derating STP po.ter cable installations have been designed in accordance with Insulated Power Cable Engineers Association (IPCEA)

publication P-46-426, 1963 " Power Cable Ampacities - Volume I

- Copper Conductors" and P-54-440, 1972 "Ampacities - Cables in Open Top Trays." The STP FSAR further requires that SkV and 15kV cables in tray be installed with spacing maintained at 1/4 of the cable bundle diameterc In general, the installa-tion of Class IE power cables was found to comply with these requirements. However, spacing had not been maintained in tray segments B1XE3FTEAE, B1XE3FTEAF and B1XE3FTEAJ. Deficiencies in cable tie down requirements were also observed in these tray segments. As a result of these observations the licensee has issued NCR CE-321 No other deficiencies were identified in this are (4) Cable Damage Although no damaged cable was found, two situations with'the potential for cable damage were identified by the NRC CAT inspectors. A number of cable tray segments above equipment II-8

were found to be missing required edge softeners where cable breaks out of the tray over the. tray side rail into the equip-ment. Numerous examples were noted in the switchgear room Based on this observation, the licensee documented an individual occurrence on NCR CE-03210 and addressed the generic issue with a procedure change. The change will add a visual check for the presence of edge softeners to QCP-10.32,

"Walkdown/ Turnover of Safety-Related Systems, Sub-Systems, Areas, or Components."

The second situation involves vertically run free air cable between-spreading rooms on elevations 60 ft. and 74 ft. The cables run through flame cut holes in metal decking with no protection provided for the cut edges. This item was subsequently documented on NCR CE-03256 for evaluatio In addition, the quantity of Class 1E cable coiled throughout the plant is of concern in that the potential for damage is increased whenever cable coils are exposed to general construc-tion activitie As a result of an NRC CAT observation, the licensee issued NCR CE-03310 to document minimum bend radius violations and other workmanship problems with cable temporarily coiled in panel C1PNZLP80 The area of cable protection merits continued licensee atten-tion.

(5) Cable Identificatio In general, the identification of Class 1E cable installations was found to be in accordance with applicable design criteri In connection with an issue which had been previously identi-fied in both licensee and Region IV inspection reports, NRC CAT inspectors noted that the color coding of numerous Class 1E cables had faded due to weathering, aging or both. In some installations fading had resulted in cable coloring which did not accurately represent the functional division of the instal-led cabl For example a purple cable (Division A) had faded to blue (Division B).

Discussions with licensee personnel and the review of the response to a previously issued nonconformance report indicates that, although color fading of Class 1E cabling does cause some confusion during performance of a visual inspection, a detailed examination of any particular cable will confirm proper routing and divisional separation based upon the divisional code applied to each cable jacket. In addition, the cable identi-fication at termination ends indicates the cable's safety divisio NRC CAT inspectors conf % ed this during the field examination of Class 1E cables but - ed that the divisional code had not been applied to cable supplied by Rockbestos. However, no examples of color fading in Rockbestos cable were identified by the NRC CAT inspectors or site inspection personne II-9

No other concerns were identified in this area.

-

(6) Terminations In general, cable termination activities performed by construction personnel conformed to requirements. However, several isolated construction deficiencies and one procedure conflict were identified by the NRC CAT inspector * Cable B1DJACC1LL, the power feed from the safety Division B battery, is trained such that it is in contact'with the battery rac This observation was subsequently recorded on NCR SE-03241 by the license * Terminal block 200 in panel A1SIABC1HH has a broken separator

'

between the positive and negative terminal points for cable A1SPAAC1S This was subsequently documented on NCR CE-03222 by the license * Cables A1SPIABCICA and A1SIABC1HH-are terminated on their respective breakers in reverse order to the specification requirements. The specification requires black,. red, orange terminated top to bottom and the cables.are terminated black, red, orange bottom to top. This was subsequently recorded

-

on NCR CE-0325 * During the inspection of control cable terminations, several adjacent cable conductors were found to violate the. require-ment for minimum bend radiu The cables involved ar A1SP25CBSC and A1SP25CBSE in panel A1PNETCA04, and cable A1SP21 COSH in panel A1PNETCA02. Based on this observation the cables were documented on NCR CE-03205 by the license QCP-10.13 Section 5.2.2.1 requires inspection for nicked or missing conductor strands. This characteristic is required for and is being recorded acceptable on inspection records for post termination inspections where the conductor strands ,

are inaccessable for-inspectio c. Conclusions With the exception of concerns or deficiencies identified in the areas of cable identification and cable damage, and the apparently isolated deficiencies identified with terminations, the installation of Class 1E circuits and wiring was found to be in accordance with applicable design requirements' .

3. Electrical Equipment Installation a. Inspection Scope Over 40 pieces of installed or partially installed electrical equipment and associated hardware items from the various safety divisions were inspecte . - . - - .

.

The following specific electrical components were inspected in detail:

(1) Motors The installation of ten motors and associated hardware was inspected for such items as location, anchoring, grounding, identification and protectio The motors inspected were:

Essential Cooling Water Pump Motor 3R281NPA101A Essential Cooling Water Pump Motor 3R281NPA101B Containment Spray Pump Motor 2N101NPA101A Containment Spray Pump Motor 2N101NPA101B Containment Spray Pump Motor 2N101NPA101C Safety Injaction Pump Motor 2N121NPA101C Essential Lnilled Water Pump Motor 3111VPA004 Reactor Makeup Water Pump Motor 3R271NPA101A EAB Air Handling Unit Fan Motor 3V111VFN014 EAB Air Handling Unit Fan Motor 3V111VFN016 (2) Electrical Penetration Assemblies

.The following containment penetration assemblies were inspected:

C1PHEP046 Instrumentation C1PHEP054 480V Power B1PHEP028 Instrumentation A1PHEP018 Control B1PHEP032 Control B1PHEP036 480V Power The location, type, mounting, identification, and maintenance 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 compsiance with design and installation documents for size, type, system interface, and maintenance:

Containment Spray Safety Injection (4) .Switchgear and Motor Control Centers The following switchgear and motor control centers were inspected:

II-11

. - - - . .

Motor Control Center B1PMMCEB1 Motor Control Center C1PMMCEC3 Motor Control Center A1PMMCEA2 Motor Control Center A1PMMCEA3 Motor Contro1~ Center A1PMMCEA4 4160V Switchgear B1PKSG0ElB 4160V Switchgear AIPKSG0E1A (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 record VDC Battery C1DJBT045D 125VDC Battery AIDJBT045A (6) 125VDC System Equipment The following equipment comprising portions of the 125Vdc systems were inspected for compliance to design documents for such items as location, mounting (welds, concrete anchors and bolting) and proper configuration:

Battery Charger B1DJBC047E Battery Charger AIDJBC047B Battery Charger AIDJBC047A Distribution Panel A1VADP1201 Distribution Panel B1DJPLO39B Distribution Panel C1DJPLO39C Static Inverter A1VAIV1201 Inverter / Rectifier A1VAIV001 (7) Control Panels A number of safety-related electrical control panels were inspected for compliance to requirements for items such as location, mounting and type. The panels inspected were:

Diesel Generator Control Panel A1PNZLP101 Diesel Generator Control Panel B1PNZLP103 Remote Shutdown Panel A1PNZLP100 B1PNZLP100 C1PNZLP100 D1PNZLP100 Main Control Boards (2)

(8) Motor Operated Valves The following 16 motor operated valves were examined in detail:

11-12

~ _ - - - _ .

i l

CICVMOV01128 B1SIMOV0001B B1CVM0V0113A CISIMOV00016 A1RCMOV0001A A1SIMOV0004A B1RCMOV0001B B1SIMOV0004A B1SIMOV0016B CISIMOV0016C B1SIMOV0018B CISIMOV0018C C1RHMOV0061B A1RHMOV0061C C1CCMOV0209 CICCMOV0199 The following documents provided the basic acceptance criteria for the inspections:

Bechtel Specification 3E319ES1040, " Class 1E' Induction Motors (250HP and Below)," Rev. 0

Bechtel Specification 4A479ES1018, " Environmental Qualification of Safety-Related Electrical and Mechanical Equipment," Rev. 2 Bechtel Specification 3E159ES0012, "5KV Class IE Metal-Clad Switchgear," Rev. 2 Bechtel Specification 3E269ES1091, "Special Electrical Penetration Assemblies," Rev. 2

Bechtel Specification 5A230ES1008, " Installation of Electrical Cable, Raceway and Equipment Identification,"

Rev. 6 Bechtel Specification SE329ES1002, " Valve Electric Motor Actuators," Rev. 3

Bechtel Procurement Appendix G, "Large AC Induction Motors for Class 1E Service (250 HP and Larger)," no revision

Ebasco QCP-10.15, " Electrical Equipment Installation Inspection," Rev. 4

Ebasco QCP-10.20, " Electrical Penetration Installation Inspection," Rev. 3 Ebasco SP-2, " Installation of Permanent Electrical and Mechanical Plant Equipment," Rev. 4

Ebasco CSP-44, " Installation of Electrical Penetration Assemblies," Rev. 3

Ebasco Construction Maintenance Instruction CMI-1, " Caring and Maintenance of Permanent Plant Items," Rev. 7

Applicable design drawings and design change documents II-13

__ Inspection Findings

. (1) Motors In general, the Class 1E motors inspected were found to conform with applicable design documents. The motors examir, d were of the type, size, and configuration specified. A limited review of maintenance records indicated that construction maintenance had been performed in accordance with approved procedure However, several specification deficiencies were found with-several 480V motors and mounting deficiencies were noted with several 4160V motor Bechtel specification 3E319ES1040 requires motors under 250 horse power (HP) rating to have vendor installed terminal lugs on the motor leads. The two air handling unit fan motors inspected, 3V111FN014 and FN016, did not have the required terminal lugs. The braided jackets on the fan motor leads were also found to be frayed. A third fan motor, FN002, identified by the NRC CAT mechanical inspectors was also found in this condition. Although these are not considered significant hardware deficiencies by the NRC CAT, the appropriate terminal lugs need to be installed when the fan motors are terminated to their permanent power source. Fans FN014 and FN016 were subsequently documented on NCR BE-03335 and fan FN002 on NCR BE-0333 The Bechtel specification also requires motors under 250 HP rating to have an insulation rating of Class F (135*C) or H (150*C). The nameplate and vendor manual for the reactor make-up water pump motor 3R271NPA101A indicate the motor insulation is only Class B (110*C). This requires evaluation by the licensee to assure the motor is adequate for its intended service environmen Approximately half of the motor hold down bolts for containment

~

spray pumps 2N101NPA101B and C and high head safety injection pump 2N121NPA101C were unmarked ana of indeterminate materia The remainder of the' bolts were marked as ASTM A-449 in lieu of the required A-193, Grade B7. These and other pump motor hold down bolt-discrepancies were subsequently dotumented on NCR-CM-03078. These are discussed further in Se.ctions III,-

Mechanical Construction, and VI, Material Traceability and Contt01, of this repor In an isolated finding, containment spray pump motor 2N101NPA101A did not have a sight glass for the upper bearing oil reservoir although the maintenance records indicated adequate oil level. The missing sight glass was subsequently documented by the licensee on Deficiency Report (DR) 1-505 (2) Electrical Penetrations The penetrations examined were found to have been installed in

<

accordance with the applicable design documents. A review of II-14

. -.

~

relevant maintenance records indicates that a number of maintenance discrepancies such as 0 psi pressure and no internal heaters were documented and adequately dispositioned on Maintenance Discrepancy forms or determined to be unneces-sary by the equipment vendo No deficiencies were observed in this are (3) CircuitBreakers

'

Thi. examination of the selected circuit breakers for the containment spray and safety injection pump motors indicated that they had been purchased, installed and maintained in accordance with the applicable design documents. Important installation attributes such as proper alignment, main contact penetration, and safety interlocks were verified by physical inspection and review of construction and test record Maintenance records were also reviewed and indicate that appropriate activities had been performe Circuit breakers which serve various 480V motor control centers were also examined and are discussed in Section II.B.3.b.4, belo No deficiencies were observed in this are (4) Switchgear and Motor Control Centers The examination of Class 1E motor control centers disclosed several deficiencies with regard to installation of circuit protection devices. NRC CAT inspectors observed that load-side terminal extensions on ITE type HE molded case circuit breakers had been attached using connecting screws which lack sufficient thread engagement to achieve and maintain a tight connectio Additionally, insulating barriers installed between the terminal extensions were found to be loose or missing. As a

~

result of this condition two concerns were noted and discussed with licensee personne (a) Potential for Inadvertent Circuit Interruption Actual measurements indicate that terminal connecting screws have an engagement of less than 1/4 inch into the circuit breaker housing. This engagement was found not to be adequate to assure that a tight connection will be maintained between the terminal and circuit breaker in a number of these installations. Many of the circuit breakers examined, including QC accepted and turnover items,. exhibited terminal extensions which were loose as received from the vendor or due to normal construction activity; i.e. , attachment of field cables or work in adjacent cubicles and wireways. The potential for inadvertent circuit interruption exists in that terminal II-15

}

. - - . - - . .

connecting screws may work' loose during construction or startup activities or due to the vibrations typically experienced during plant operatio (b) Phase to Phase Faultina As detailed in (a), above, many of the Class IE circuit breakers examined contained loose terminal extension The' length and spacing of these extensions was such.that phase to phase contact is possible. . Additionally, many of the insulating barriers installed between terminals were loose or missing due to inadequate vendor-installation or construction or startup damage. As a result, the potential for phase to phase faulting exist _

, These concerns were. discussed with licensee personnel in an attempt to determine the reason for use of load terminal

'

extensions on molded case circuit breakers at South Texas Project, and why the previously mentioned deficiencies had not been identified by site inspection or source surveillance personne These discussions and a review of the relevant Bechtel purchase specification, 3E179ES1054, indicate that although the specifica-tion does detail a requirement for breaker terminals which can accomodate attachment. of a two hole termination lug, no specific renuest for use of terminal extensions had been made

.

by the licensee to the motor control center vendo It was also observed that load terminal extensions were not-detailed on any of the applicable. design and vendor documents available for review.- Additionally, based upon review of relevant vendor ,

documentation and the equipment seismic qualification report it could not be determined whether the Class 1E motor control centers had been tested with circuit breakers in this ~

configuration. As a result of this observation and at the request of NRC CAT inspectors, Bechtel engineering issued

~

letter ST-YB-00-74 to the motor control center vendor (Telenecanique) requesting additional information on this subject. No response had been received from the vendor during the NRC CAT inspectio During meetings with the licensee regarding the possible reasons for use of the terminal extensions, the licensee's criteria for cable sizing were discussed. At the request of the-NRC CAT, the licensee evaluated the cable sizes and limiting factors for the Unit 1 circuits connected to breakers'with terminal extensions. Their evaluation showed that although the cables for several circuits were one size larger than required, all the circuits but one could be terminated directly to their breakers. The one circuit with terminal lugs too large for direct connection to its breaker (MCC E1A4, cubicle F3L) was size limited for ampacity and not voltage drop. Prior to the NRC CAT inspection, the licensee had identified one circuit with a cable size limited due to II-16

voltage drop (MCC E1C2, cubicle H2R) and has since re-routed the circuit eliminating the voltage drop proble As a result of deficiencies identified in this area the licensee has issued NCRs BE-03208 and SE-03201 to document and identify the extent of this problem. Preliminary reviews indicate that approximately 30 Unit 1 Class 1E circuit breakers exhibit this configuration with an equal. number existing in Unit See Table 11-4 for a listing of motor control centers, breakers, and safety-related loads affected by this conditio On November 18, 1985, the licensee notified NRC Region IV that this issue is potentially reportable pursuant to 10 CFR 50.55(e).

In general, the installation of Class 1E 4160V switchgear was found to be in accordance with requirements. Attributes.such as location, mounting and installed configuration were as specified by. approved design document However, several specification deficiencies were identifie Appendix C of Bechtel specification 3E159E50012 establishes requirements for control wiring within SkV metal-clad switchgea *

Subsection E states in part..."The preferred terminal blocks are G.E. Catalog CR-151B2, connection U2 or connection NU Each terminal block shall have no less than 12 points." Contrary to this requirement NRC CAT inspectors identified severai cubicles of the 4160V

'tchgear which contain terminal blocks with less than t'w 12 points specifie *

section Q states in part'.." Adequate space shall be

.

t c .ded on both sides of the terminal blocks for connect-ing wires and wire markers. To allow for stripping and bending on incoming cables, terminal strips shall be located a minimum of 8-inches away from cable entrances either at top or bottom." Contrary to this requirement NRC CAT inspectors observed the location of terminal strips to be less than 8 inches from cable entrances in several switchgear cubicle These specification deviations were observed in several cubicles of 4160V switchgea As a result of this observation the licensee has issued NCR SE-03225 and initiated Specification Change Notice SCN-3 to document and correct this conditio No other deficiencies were identified with 4160V switchgea II-17

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

(5) Station Batteries and Racks The condition of the battery rooms was found to be in good order and 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 prohibit smoking or open flames.-

The 125V batteries were examined and found to be in good condition. Maintenance _ activities were reviewed, and in general, had been performed in accordance with requirement The inspection of the 125V battery-racks disclosed that indeterminate bolting materials had been used in the assembly process. This issue is discussed in detail in Section VI, Material Traceability and Control, of this report.

(6) 125VDC System In' general, the examination of components which comprise portions of the 125Vdc system indicates that construction activities had been accomplished in accordance with the applicable procedures and design documents. However, deficiencies in the area of equipment mounting and product quality were identified on several pieces of Class IE equipmen The examination of distribution panels B10JPLO39B and C1DJPLO39L disclosed a weld configuration which does not match the mounting details specified by applicable design document Field Change Request (FCR) CE-04475 specifies a 1/4 inch fillet weld of 4 inches length on 6 inches centers to be installed on two sides of the equipment and a continuous 1/4 inch fillet weld on the front. Actual field conditions exhibited a 1/4 inch fillet weld on 8 inches centers on both front and sides of the panel Relevant inspection records which indicate acceptable irstallations do not account for this discrepanc As a result of this observation the licensee has issued NCR SE-03325 to document and correct this condition.-

Each of the three Class 1E battery chargers examined by the NRC CAT exhibited loose soldered connections on the equipment " firing boards." Inadequate solder joints were observed at both pin-to-conductor and pin-to-circuit board connections. Discussions with licensee personnel revealed that this condition had been identified and evaluated on Startup Work Request (SWR) 01757, and that, pending delivery of qualified solder material, approved corrective action would be implemente No other deficiencies were identified in this are II-18

i l

,

(7) Control Panels In general,-the installation of Class 1E control panels was found to be in accordance with applicable requirement Mounting, location, and installed configuration were as specified. Several discrepancies were identified with regard to fastening materials used in the assembly of some panel This issue is discussed in detail in Section VI, Materia Traceability and Control, of this repor ~

The NRC CAT inspectors also noted several non-Class 1E equip-ments with identification tags color-coded as Class IE equip-ment. Ten nonsafety relay panels had white identification tags which indicate safety Division D 'and the nonsafety heater in an emergency diesel generator high voltage panel had a blue tag indicating safety Division B. The licensee .bsequently documented the relay panels o'n DR E-0632 and all three diesel generator high voltage panels on NCR BE-03300 for corrective action.

(8) Motor Operated Valves The NRC CAT -inspected 16 valve operators for installation to the latest design requirements and identified deficiencies in all 16 operatort examined. In addition, discrepancies were found in the control and execution of design changes to certain motor operated valves (MOVs) supplied by Westinghouse Corporation (W).

Several deficiencies were noted in virtually all of the MOVs inspecte These included loose vendor terminations,-jumper wires containing bend radius violations, and the use of No. 16 AWG wire in lieu of No. 14. In addition, the licensee was unable to provide the NRC CAT with evidence of qualification for the No.16 wire. Other deficiencies were noted in one or more operators and included more than two wires on one terminal point, duct seal melted onto terminal points, unidentified terminal points, Raychem wire installed in lieu of the required Fire Wall III wire , a cracked terminal lug, and damaged conductor The damaged conductors and several of the minimum bend radius violations appear to be generic to Limitorque model SMB operators due to the minimal clearance between the cover anr1 the rotor. Table II-5 lists the MOVs inspected and the ficiencies found with each. The licensee subsequently issued hCR BE-03209 to document the deficiencies observed by the NRC CAT in valve motor operator During the first week of inspection the NRC CAT inspectors observed in process field wiring changes in motor operated valves and attempted to verify their field installation. A number of problems ~ arose resulting in the investigation continuing through the final weeks of the NRC CAT inspectio The sequence of events is as follows:

II-19

• NRC CAT inspectors observed design changes being performed during implementation of Configuration Control Package (CCP)

'1-N-WN-0021 by Westinghous * NRC CAT's field. verification of.CCP 0021 resulted in the identification of numerous hardware deficiencies as discussed abov ~

• NRC CAT inspectors requested CCPs for ongoing design changes with MOVs and were provided CCPs 1-E-EM-0243.and 1-E-ST-033 The subsequent NRC CAT evaluations of these packages resulted

"

in the identification of conflicts with CCP 002 * Based on NRC CAT observations and licensee reviews of the identified problems for MOVs, the licensee issued a voluntary stop work orde * No further documentation was provided to the NRC CAT, pending the completion of a review of the overall MOV problem by the license * The licensee. informed NRC Region IV of a potentially reportable deficiency relating to the wiring of MOV CCPs-0021 and 0339 were initiated by W FCNs to modify valve closure indications and bypass an unqualified terminal block respectively. CCP 0243 was initiated by Bechtel to brirg the valve operators up to Bechtel's current design. -W was per-fonning the work and QC inspection under CCP 0021 while .

Ebasco was making the design changes under CCPs 0339 and 024 While performing the wiring changes under CCP 0021, W added additional jumpers outside the stated scope of the CE The NRC CAT review indicated that these jumpers were the same as several jumpers being removed by Ebasco under CCP 0243. The review also showed that one of the required jumpers of CCP 0021 was being deleted by CCP 0339. In addition, jumpers had been added to several MOVs such that a continuous close indica--

-tion would be displayed regardless of the actual valve posi-tion.- These jumpers were required by and installed in accordance with the site's EE-580 field wiring program. These NRC CAT observations indicate that there was a lack of coordi-nation for the sequence of work for'the CCPs and between the '

CCPs.and the ongoing EE-580 progra This also indicated inadequate control of wiring changes for the MOVs and the potential for installed wiring not conforming to desig When an earlier wiring discrepancy in a motor operator was identified by Ebasco under CCP 0243, Bechtel issued Engineering Request for Site Action (ERSA) 0121-E in September 1985 to determine, the actual wiring configuration of 58 W MOV Discussions with the licensee and Bechtel at the site and Bechtel's Houston office regarding the design changes being !

made to the W MOVs indicated several items:

l II-20 '

_

..

• The status of QC . inspection for the design changes is indeterminat * The licensee was unable to specifically identify the original wiring diagram which represented the configura-tion of the MOVs as they were received and upon which design changes were being base * Bechtel changes to MOV wiring were not appropriately reviewed by W'or provided for incorporation into W design drawing A similar problem in another area was identified in a licensee audit report S15-501 dated April 15, 1985. This is discussed further in Section VII, Design Change Control, of this repor * Bechtel verification of the ERSA as-built wiring details revealed discrepancies between the reported configuration and the actual configuration of the MOVs. As a resu'.t of these observations the licensee has initiated a walkdown to .

establish the current wiring configuration of Class 1E MOV Further discussions with the. licensee revealed that an MOV inspection program was being planned because of a history of problems reported by vendors, other sites, and the NR However, the documents provided to the NRC CAT, specifically Bechtel Interoffice Memorandum 10M-3885S dated October 21, 1985,.with the subject " Problems Associated with Limitorque Valve Operators," propo w d a sample surveillance of only warehoused valves. Such a program would not have identified all the problems found with the installed MOV As a result of the continued problems witn the valve motor operators, the constructor instituted a r luntary stop work order on November 13, 1985, and the licensee informed NRC Region IV on November 19, 1985 of a potentially reportable item under 10 CFR 50.55(e).

The interface for design between the A/E and NSSS is further discussed in Section VII, Design Change Control, of this repor In summary, numerous hardware deficiencies were found with the MOVs inspecte In addition, a lack of effective design change control for the wiring of W supplied valve motor operators has resulted in the licensee not being certain as to their wiring baseline or current configuration. Corrective action by the licensee is required to assure that all safety-related MOVs meet their required design configuratio An ancillary concern was rais*.( by the NRC CAT inspectors during discussions with the licensee regarding the control of design documents for MOV wirin It was noted that Bechtel's elementary wiring diagrams, wnich are the controlled design documents, did not provide point-to point wiring informatio II-21

The NRC CAT inspectors were concerned that HL&P startup and operations personnel would need point-to-point information for perfoming tests, troubleshooting and modifications. The discussions with Bechtel indicated that they would review this issue, c. Conclusions In general, the installation of Class IE equipment conforms to design requirements. However, of concern were the hardware deficiencies identified in Class 1E motor control centers and motor operated valves, and the specification c'eviations identified in Class IE switchgear and motor The examination of ITE type HE molded case circuit breakers disclosed deficiencies with regard to attachment of load-side terminal extensions. Consequently, installations which exhibit this configuration have the potential for inadvertent circuit interruption or phase to phase faultin Numerous hardware deficiencies were identified in the wiring of V0Vs. A lack of effective design control for the MOV wiring has'

resulted in the inability to correlate their actual configuration to the required desig Several cubicles of Sky switchgear were found to deviate from the applicable specification requirements for the location of terminal strips and the minimum number of teminal block points. Four motors were also found to deviate from their applicable specification. Three air handling unit fan motors did not have the required vendor installed terminal lugs, and the insulation of a reactor makeup water pump motor is Class B in lieu of the required Class F or H.

4. Instrumentation Installation a. Inspection Scope The NRC CAT inspectors selected a sample of 10 installed and inspected instruments for examination to requirements for location, mounting details, and instrument type and range. The instrument tubing for these instruments were also examined to specification, procedure, and isometric drawing requirements. A total of 16 supports from these runs were also inspected. Table II-6 details the inspection sample for the instrumentation installatio In addition, the internal wiring configuration of an instrumentation process panel was verifie The following documents provided the acceptance criteria for the inspection:

II-22

• Bechtel Specification 4Z519ZS1040, " Instrument Installation Seismic Category 1," Rev. 3

Ebasco QCP-10.13, " Mechanical Instrument Installation luspection," Rev. 4

• Fbasco CSP-47, " Instrument Installation," Rev. 4 Findings The sample of instruments inspected by the NRC CAT represents half of all the instruments the licensee had inspected, accepted and turned over to the startup organization at the time of the NRC CAT inspection. The limited sample examined revealed numerous construction deficiencies and several program weaknesse Deficiencies were found in the installation of the instrument-or tubing in eight of the ten instr 2ments inspected. .The deficien-cies found with more than' one installation included out of tolerance dimensions, and loose conduit fittings._ Other deficiencies which appear isolated to individual installations included a hanger weld not meeting the drawing configuration, the actual instrument identi-fication not corresponding to the drawing, a missing tubing clamp, and a loose pressure transmitter. Two weaknesses were also identi-fied through the installation inspections. These were QC inspec-tions performed with drawing revisions other than the latest revision, and existing supports used without the required engi-neering approval. The deficiencies were subsequently recorded on nonconformance documents by the licensee. Table II-7 details the findings for the eight instrtnent instellations with deficiencie Discussions with the licensee indicated that a sample surveillance of. instrument installation was being performed under their QC Effectiveness Inspection Program. Two of the five instrument A1EWFT6854 and C1EWFT6873, inspected by the Effectiveness Program coincided with the NRC CAT sample. Although the Effectiveness Program has identified installation deficiencies similar to those found by the NRC CAT, they failed to identify the out of tolerance dimensions found with the installation of C1EWFT687 The NRC CAT inspectors verified wiring changes conducted under CCP 1-N-WN-0083 (W FCN TGXM-10585 Revs. A, B, C) to instrument process panel 3Z121ZRR018. Attributes such as circuit board changes, point-to-point wiring changes, wire type and size, and contrasting wire color met'the CCP requirements. However, the jumper locations on two circuit cards were not as required. The jumpers on the circuit cards in locations C3-247 and 248 are in the "high" position while the CCP requires them to be in the " low"

~

position. This discrepancy was subsequently documented on NCR SE-03341. In additon, HL&P's Station Procedure OPCP03-ZM-0011

" Plant Instrumentation Scaling Program" has provisions for document-ing the configuration of circuit cards with jumpers or plug-in components for use in calibrating.and testing process instrumenta-tion by plant staf II-23 Conclusions The number of construction deficiencies found in the limited sample

~o f. instrumentation indicates that the licensee's inspection and surveillance programs are not completely effective. In addition, weaknesses were identified in the use of latest drawing revisions

.for i.nspections and obtaining required engineering approval for additional attachments to existing supports. This area requires additional management attentio !

II-24 i

l

TABLE II-1 RACEWAY INSPECTION SAMPLE Cable Tray:

B1XC4ATHAP B1XC4ATHAG B1XC4ATHAF B1XC4ATHAE B1XC4ATHAD B1XC4ATHAC B1XC4ATHAB B1XC4ATHAA B1XC4BTHAA B1XC4BTHAB B1XC4BTHAC AIXE1HTTAM AIXE1HTTAG AIXE1HTTAH AIXE1DTTBH AIXE1DTTBG A1XE1DTTBF AIXE1DTTBE AIXE1DTTBD AIXE1DTTBC AIXE1DTTBJ A1XE1DTTBK AIXV1ATSAA AIXVIATSAB B1XE3FTHAN B1XE3FTHAP B1XE3FTHAR B1XE3FTHAS B1XE3FTHAT B1XE3FTHAU B1XE3FTHAF B1XE3FTHAE B1XE3FTHAD B1XE3FTHAC .B1XE3FTHAB B1XE3FTHAA B1XE4GTHAA B1XE4GTHAB -AIXFIBTJAG AIXF1BTJAF AIXF1BTJAE AIXF1BTJAB A1XF1BTJAA AIXF1BTJAH A1XF1BTJAV AIXF5AKTVA AIXF5AKTAB A1XF5ATTAA A1XF5ATJAA AIXM4KTJAC AIXM4KTJAB AIXM4KTJAA A1XM4JTJAB AIXM4JTJAA AIXM4DTJAS A1XM4CTJAB AIXM4CTJAA A1XM4BTJAC AIXM4BTJAB AIXM4BTJAA C1XG1ATSAN C1XG1ATSAM C1XG1ATSAG C1XG1ATSAF C1XG1ATSAE C1XG1ATSAD C1XG1ATSAC C1XGIATSAB C1XG1ATSAA Cable Tray Supports:

1-019-H109 1-106-H4 2-103-H23 1-100-H51 1-019-H704 2-002-H3 1-105-H30 2-103-H41 2-002-H47 1-105-H702 2-103-H92 2-002-H23 1-152-H109 2-103-H61 Conduits:

Number Length (Feet) Number Length (Feet)

~A1XC4DRJ004 100- B1XE2ARY005 79 AIXC4DRT005 100 B1XE2ARY006 79 A1XE1FRS006 32 B1XF1BRS008 89 A1XE1FRH001 35 B1XM2ER5073 48 A1XElGRLO33 49 B1XM3ERJ068 33 AIXElGRLO32 44 C1XF1ARH004 55 A1XE2ARY102 51 C1XF1ARS004 67 AIXE2BRX004 39 C1XFIARS010 63

'A1XF1BRF001 64 C1XF1FRS009 45 AIXF1BRF002 58 C1XM3ERS204 39 A1XF1BRF003 49 D1XElGR2037 15 A1YC4 DRY 003 95 D1XElGRX002 30 B1XE2ARY003 79 D1XE2BRX004 84 B1XE2ARY004 79 D1XE2CRS081 32 II-25

TABLE II-1 - (Continued)

RACEWAY INSPECTION SAMPLE

. Conduit Supports:

~ 1120005 1532512 1625783 1120008 1541547 1651000B

'1134931 1613130 1651001 1134932 1613132 1654548 1153322 1625779 i

,

Y

l'

'II-26 L

TABLE II-2 SEPARATION FINDINGS Raceway segments listed in the A columns do.not maintain required separation from the corresponding raceway segments in the B columns. The (*) indicates physical separation of less than one inch between the two raceway segment Column A Column B Column A Column B AIXE1HTTAM NIXE1HTTAD AIXE1DTSBB N1XE1DTSAA D1XE1HTXAJ N1XE1HTYAH AIXE1DTXBB N1XE1DTCAA AIXE1DTHBH- N1XE1DTJAV A1XE1DTXBS N1XE1DTCAC AIXE1DTXBB N1XE1DTYAA AIXE1DTXBC NIXE1DTXAE A1XE1DTXJB N1XE1DTHBF A1XE1DTHBK N1YE1DTHAX AIXM4KTYAC N1XM4KTYAC AIXF1BTFAF * N1XF1BRJ011 A1XM4JTYAA N1XM4JTTAA AIXM4JTJAA N1XM4JTYAA A1XM4CTYAA N1XMiCTYAA A1XM4BTJAC NIXM4BTSAE AIXM4BTJAC N1XM4BTJAE AIXM4BTYAF N1XM4BTYAC AIXM4BTFAB NIXM4BTHAC AIXM4BTFAB NIXM4BTTAC B1XC4ATHAJ NIXC4ATAAJ AIXM4BTFAB * N1XM48R031 B1XC4ATHAP N1XC4ATHAJ B1XC4BTJAE * N1XC1BRX278 B1XC4BTXAF N1XC4BTHBA B1XCABRT852 * N1XC1BRX278 B1XE4GTHAB N1XE4GTHBA AIXE2ARY102 * C1XE2ARY103 B1XM1ERYO48 AIXM1MTYAB II-27

TABLE II-3 TCPMINATIONS Location Termination Description A1B52RR014 A1BSAAC23B Control Cabinet A1BS2RR014 A1SP12C1XA2 Control Cabinet Plug A1CCMOV0050 A1CC04C1WA2 MOV A1MB2CP1822 A1AM10C1XA2 Control Panel A1PMMCEA152 A1AF01C1WA1 MCC EIA1 A1PMMCEA1G1 A1RH03C1WD1 MCC E1A1 A1PMMCEA1V42 A151AAC1HJ2 MCC ElAl A1PMMCEA2F3 A1SP23CASC2 MCC E1A2 A1PMMCEA2J3 A1SP23 CASA 2 MCC EIA2 A1PMMCEA2R2 A151ABCILA MCC E1A2 A1PMMCEA2R3 A1S1ABC1HH1 MCC ElA2

'A1PMMCEAA2E1 A1CC04C1WC1 MCC E1A2 A1PMMCEAE1 A1CC04CID1 MCC E1A2 A1PN2LP10052 A1AF01C1WE2 Control Panel A1PN2LP100S2 A1AF0361WF2 Control Panel AIPN2LP659 A1AF01C1SA2 Control Cabinet A1PN2LP700 A1AP02C1WB1 Control Panel A1PN2LP700 A1AP02C1WA2 Control Panel A1PN2LP801 A1AF01C1WF2 Control Panel A1PNERR118A A1AF05C1WA2 Control Panel A1PNERR130A A1AF08C1WA1 Control Panel A1PNERR130A A1CC2VC1WA1 Control Panel A1PZRR002-2 A1SP17CCSA1 Control Cabinet A1502R0011 A1SP12C1XC1 Control Cabinet Plug A1502RR008I A1SP12C2XA1 Control Cabinet Plug A1S12RR051 A15129C1XB2 Control Panel A1SP2RR001I A1SP12C1XB1 Control Cabinent Plug A1SP2RR002-1 A1SP27CCSC1 Control Cabinet A1SP2RR002-2 'A1SP17CHSB2 Control Cabinet A1SP2RR0081 A1SP12C2XB1 Control Cabinet Plug A1SP2RR002-1 A1SP27CCSB1 Control Cabinet A1SP7RR002-2 A1SP17CDSA1 Control Cabinet B10SPLO37C7 B1PKACCILA1 DC Switchgear B1852RR017 BIBSABC26A2 Control Cabinet B1B52RR018 B1HC30C1XB-1 Control Cabinet 81DJBC047E B1DJACCILG1 Charger / Inverter B1DJBC047F B1DJACC1LH1 Charger / Inverter B1DJBT045LN B1DJACCILL2 Battery-B10NERR137 B1HC18C1SD2 Control Cabinet B1FMMCEB1J1 B1HC20C2SC1 MCC E181 I B1MB2CP22T11 B1HC18C1SC2 Control Panel BlMB2CP4T30 BlMB04C1501 Control Panel B1MB2CP4T30 BlMB04C1SS1 Control Panel B1M82CP4T30 B1MB04CIST1 Control Panel B1PK2GD0E183 B1SP22CUSB2 MCC E182 B1PKSG0E187 B1EW01C2WH1 4160V Switchgear EIB B1PMMCEB122 BlAF03C2WC1 MCC E181 B1PMMCEB1F1 B1CCADC1LC1 MCC ElB1 B1PMMCEB1F3 B1HC18CISE1 MCC E181 II-28

TABLE II-3 - (Continued)

TERMINATIONS Location Termination Description B1PMMCEB1LIL B1CCADL1LK1 MCC ElB1 B1PMMCEB1P3 B1CCADC1LM1 MCC E181 B1PMMCEBIR2 B1AF03C2WA1 MCC E181 B1PMMCEBIT1 B1CC1C1WA1 MCC ElB1 B1PMMCEB203 B1CC0525El MCC ElB2 B1PMMCEB253 B1CHABC2LB1 Distribution Panel B1PMMCEB2F3 B1CC642WD1 MCC E182 B1PMMCEB2F3 B1CC04C2WC1 MCC ElB2 B1PMMCEB2G B1C006C2SB1 MCC E182 B1PMMCEB2G1 B1CC06C2SC1 MCC ElB2 B1PN2LP654 B1AF01C2WD1 Control Panel B1PN2LP660 B1CC06C2SA2 Control Cabinet B1PN2LP678 B15129C1XB1 Control Panel B1PN2LP678 B1HC30C1XB2 Control Panel B1PN2LP678 B1B509C1XA2 Control Panel B1PN2LP802 B1CC01C2WB2 Control Panel B1PNERR1208 B1C010CBSB Control Panel B1PNERR121B B1CC01C2WA2 Control Panel B1PNTB678 BlAMABC2SR1 Termination Box B1512RR052 B1S129C1XC1 Control Panel BISP2RR004-1 B1SP22CMSD Control Cabinet B1SP2RR004-1 B1SP24CASD1 Control Cabinet 81SP2RR004-1 B1SP24CASB1 Control Cabinet 81SP2RR004-2 B1SP22CUSA1 Control Cabinet B1SP2RR004-2 B1SP22CVSD1 Control Cabinet B1VA1V1203 B1VAACCILA2 Charger / Inverter C1BS2BR019 C1FW11C2PA1 Control Cabinet C1BS2RR019 C1CV10C5PA2 Control Cabinet C1BS2RR019 CIRC 10C7PB1 Control Cabinet C1DN2LP679-1 C1FW23C9XC2 Control Panel ClMB2CD4T50 C1MB04C1SF1 Control Panel ClMB2CP1T35 C1B504C1XA2 Control Panel C1MB2CP1T35 C1MB01C1SC1 Control Panel ClMB2CP3T45 C1MB03C15El Control Panel C1MB2CP3T45 C1MB031SE1 Control Panel C1MB2CP4T50 ClMB04CISG1 Control Panel ClMB2CP4T50 C1MB04CISH1 Control Panel C1PN2LP10055 C1AMACG1SC2 Control Panel C1PN2LP679 CIAMACCISG2 Control Panel C1PN2LP679 C1RA13C1XB2 Control Panel C1PN2LP679 C1RA13C1XH2 Control Panel C1PNETCC01 ClMB04C1SH2 Control Cabinet C1PNTB679 C1AMACC15G1 Termination Box D1DJBC047D D1DJABCILG1 Charger / Inverter 01DJBC047G D1DJABC1LB1 DC Switchgear D1DJPLO37813 D1AF09C1SL1 DC Switchgear D1DJPLO37B3 D1DJABC1LG2 DC Switchgear D1DJPLO37B4 D1VAABC1LA1 DC Switchgear 11-29

"

i TABLE II-3 - (Continued)

'TERNINATION ~ Location Termination Description  !

D1DNERR141 D1PNAEC3SA2 Control Cabinet D1M82CP1817 D1CC17CISA2 . Control Panel 01PNERR1240 01CC17C1SB1 Control Panel DIPMERR124P DIPN10CNA2 Control Panel DISP 2RR0011 DISP 12C1XC1 Control Cabinet Plug DISP 2RR008I DISP 12C2XA1 Control Cabinet Plug i DISP 2RR0081- DISPT2C2VB1 Control Cabinet Plug.

,

DISP 2RR008I DISP 12C2XC Control Cabinet Plug :

' DISP 2RR008I- Control Cabinet

'

DISPABCISB2 01VADP1202 D1BSA8CISA1 Distribution Panel D1VATV11202 D1VAABC1LA2 Charger / Inverter V

i l

l l

I l-l

>

.

'

l

!

II-30

-

>

L l

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

m TABLE'II-4 UNIT l' CLASS 1E E0UIPMENT AND LOADS AFFECTED BY MOLDED CASE CIECUIT BREAKER DEFICIENCIES

.

Motor Control Center: 3E171MCE1A2 Cubicle / Breaker Type: A4L/HE3-8050 Class 1E Load: Distribution-Panel Transformer Motor Control Center: 3E171EMCE1A4 Cubicle / Breaker Type: C1R/HE3-8015 Class 1E Load: Containment Hydrogen Monitoring Panel Cubicle / Breaker Type: C1L/HE3-8015 Class 1E Load: 120Vac Distribution Panel Inverter Channel II Cubicle / Breaker Type: C3R/HE3-B030 Class 1E-Load: -Spare Cubicle / Breaker Type: C3L/HE3-B015 Class 1E Load: Battery Room Reheat Coil Cubicle / Breaker Type: EIR/HE3-8040 Class 1E Load: Accumulator 1A Discharge Isolation MOV Cubicle / Breaker Type: E1L/HE3-B015 Class 1E Load: Containment Cubicle Exhaust Fan Cubicle / Breaker Type: F3R/HE3-8050

-

Class 1E Load: Voltage Regulating Transformer Cubicle / Breaker Type: F3L/HE3-B100 Class 1E Load: Battery Room Charger Cubicle / Breaker Type: H3R/HE3-B030 Class 1E Load: Spare Cubicle / Breaker Type: H3L/HE3-8015 Class 1E Load: Battery Room Reheat Coil Cubicle / Breaker Type: J2R/HE3-8050 Class 1E Load: Distribution Panel Transformer Cubicle / Breaker Type: J2L/HE3-B015 Class 1E Load: Starter for Chiller Oil Lamp II-31

--

TABLE II-4 (Continued)

UNIT'l CLASS 1E EOUIPMENT AND LOADS AFFECTED BY HOLDED CASE CIRCUIT BREAKER DEFICIENCIES

.

- Motor Control Center: 3E171EMCE184 Cubicle / Breaker Type: B2R/HE3-B015 Class 1E Load: Starter for Chiller Oil Pump Cubicle / Breaker Type: B3R/HE3-8015 Class 1E Load: Spare Cubicle / Breaker Type: B3L/HE3-8015 Class 1E Load: Containment Cubicle Exhaust Fan Cubicle / Breaker Type: C2L/HE3-B015 Class 1E Load: Battery Room Reheat Coil Cubicle / Breaker Type: C2R/HE3-8030 Class 1E Load: Spare Cubicle / Breaker Type: C3R/HE3-8030 Class 1E Load: EAB Main Area Heating Coil Cubicle / Breaker Type: C3L/HE3-8030 Class 1E Load: Spare Cubicle / Breaker Type: E4R/HE3-8020 Class 1E Load: Spare Motor Control Center: 3E171EMCEIC.!

Cubicle / Breaker Type: H2R/HE3-B050 Class 1E Load: Heat Tracing Transfomer

~~

l Motor Control Center: 3E171EMCE1C4 Cubicle /Breater Type: C3R/HE3-8040 Class 1E Load: Accumulator 1C Discharge Isolation MOV Cubicle / Breaker Type: C3L/HE3-8015'

Class 1E Load: Containment Cubicle Exhaust Fan l Cubicle / Breaker Type: D1R/HE3-8015 l

Class 1E Load: 120Vac Distribution Panel Inverter

'

Cubicle / Breaker Type: D1L/HE3-8050 Class IE Load: Power Distribution Panel Transformer l

l

-

( II-32

L

. _

TABLE II-4 (Continued)

. UNIT 1 CLASS 1E EQUIPMENT AND LOADS AFFECTED BY MOLDED CASE CIECUIT BREAKER DEFICIENCIES Cubicle / Breaker Type: D3R/HE3-B015 Class 1E Load: ' Spare Cubicle / Breaker Type: D3L/HE3-8015 Class 1E Load: Containment Hydrogen Monitoring Panel Cubicle / Breaker Type: LElR/HE3-8015 Class 1E Load: Starter for Chiller Oil Pump Cubicle / Breaker Type: E1L/HE3-8015 Class 1E Load: Battery Room Reheat Coil 11-33

_ _ - - _ _ _ _ - _ _ - - - _ _ - - - _ - _ _ - _ _ _ _ _ - _ _ _ _ _

- TABLE II-5 VALVE MOTOR OPERATOR DEFICIENCIES Motor Operated Valve CICVMOV0112B:* Jumper wires contain bend radius violation ,

i Loose vendor terminations on the power terminal block, heater coils, and l torque switch points 24, 25, 26, and 2 .' No. 16 AWG wire is installed in lieu of No. 14 AWG wire on the limit switch between points 22 and 37 and between points 11 and 3 More than two-wires terminated under one terminal poin Motor Operated Valve B1CVMOV113A:* Loose vendor terminations on the terminal blocks, heaters, and limit switche No. 16 AWG wire used in lieu of No. 14 AWG wir Jumper wires contain bend radius violation More than two wires terminated under one terminal poin Motor Operated Valve A1RCMOV0001A:* Loose vendor terminations'on the terminal blocks, craters, and limit switche No. 16 AWG wire is installed in lieu of No. 14 AWG wir Jumper wires contain bend radius violations.

l More than two wires terminated under one terminal poin Motor Opreated Valve BIRCMOV0001B:* Loose vendor terminations on the terminal blocks, heaters, and limit

!

switche No. 16 AWG wire is installed in lieu of No. 14 AWG wir Jumper wires contain bend radius violation 'More than two wires tenninated under one terminal poin II-34

_ _ _ _ _ _ _ _ _ - _ _ _ _ _

TABLE II-5 - (Continued)

VALVE MOTOR OPERATOR DEFICIENCIES Motor Operated Valve B1SIMOV00018:* Loose vendor terminations on the terminal blocks, heaters, and limit switche Lug at terminal point 26 was cracked and then broke off during inspectio Jumper wires contain bend radius violation More than two wires terminated under one terminal point.

Motor Operated Valve CISIMOV0001C:* Jumper wires cont'ain bend radius violation Loose vendor terminations on the power terminal block, heater coil and torque switch points 24, 25, 26, and 2 More than two wires terminated under one terminal point.

Motor Operated Valve A1SIMOV0004A:* . Loose vendor terminations on the terminal blocks, heaters, and limit switche An additional jumper was installed which was not on drawing 9-E-SI13, sheet 1 DS Jumper wires contain bend radius violation More than two wires terminated under one terminal point.

Motor Operated Valve B1SIM0V0004B:* Loose vendor terminations on the terminal blocks, heaters, and limit

. switche Duct seal used to cover temporary power cabic opening has melted onto the termination point Jumper wires contain bend radius violation More than two wires terminated under one terminal poin II-35

.

'

,

TABLE II-5 - (Continued)'

' VALVE MOTOR OPERATOR DEFICIENCIES-

.

Motor Operated Valve B1SIMOV0016B:*

a .' Loose 1 vendor terminations on the terminal blocks, heaters,:and limit ;

switche '

. Jumper wires contain bend radius violation More than two wires terminated under one terminal poin I

MotorL0perated Valve CISIMOV0016C:* Loose vendor terminations on the terminal blocks, heaters, and limit switche C Jumper wires contain bend radius violation Terminal point 10 is not identifie . .More than two wires-terminated under one terminal poin .{

Motor Operated. Valve B1SIMOV00188:

i Loose vendor terminations on the terminal blocks, heaters, and limit switche Temporary power cable is shorting against the MOV housing and the vendor wires.to'the heater have been deformed by the cover installatio j Jung r wires contain bend radius violation ' No. 16 AWG wire in lieu of No. 14 AWG wire is installed between-points 22 and 3 ;

- More than two wires terminated under one terminal poin Motor Operated Valve CISIMOV0018C:* Loose vendor terminations on the terminal blocks, heaters, and limit switche Numerous jumper wires contain bend radius violation ;

c .- . Wire manufactured by Raychem was installed on site instead of '

Firewall III as require ,

. .

s

'

. TABLE II-5 - (Continued)

VALVE MOTOR OPERATOR ~ DEFICIENCIES f (Jumperwirescontainbendradiusviolation .More than two wires. terminated under one terminal' poin ~

MotorOperatedValveN1RHMOV0061C:*- Loose vendor terminations'on.the terminal blocks, heaters, and. limit

. switche No. 16 AWG wire'is installed in lieu of No. 14 AWG wir " A jumper between point 35 and 36 has been installed that is not identified on the scheme drawing; 9-E-RH02, sheet ' Jumper. wires contain bend radius violation e. ' More than two wires terminated under one terminal poin Motor Operated Valve C1CCMOV0209:

a '. Damaged conductors.from. removal /re-insta11ation of motor-operated valve cover. -(This appears to be a generic problem due to lack of cover / rotor clearance'on limitorque SMB models). Jumper wires contain bend radius violation Motor Operated Valve CICCMOV0199:

~ Insufficient motor operated valve cover clearance with wires on top'of rotor (Similar to problem with CICCMOV0209). Jumper wires contain bend radius violation N'TES:

O

• Def.iciencies for these valves were subsequently recorded on NCR BE-03209 by

.the licensee.

'

.

l II-37

E TABLE II-6 INSTRUMENTATION INSPECTION SAMPLE Hangers:

Field Sketch Hanger Field Sketch Harger-IC-EW-02 A IC-EW-03 F IC-EW-02 B IC-EW-03 G IC-EW-02 'C IC-EW-03 H IC-EW-03 A IC-EW-0 I IC-EW-03 B IC-EW-03 J IC-EW-03 C -IC-EW-05 A IC-EW-03- D IC-EW-12 A IC-EW-03 E IC-EW-12 C Tubing:

Field Sketch Field Sketch IC-CC-22 IC-EW-09 IC-EW-02' IC-EW-10 IC-EW-03 IC-EW-11 IC-EW-04 IC-EW-12 IC-EW-05 IC-EW-13 Instruments:

A1EWFT6854 CICCFT4522 A1EWFT6856 C1EWFT6873 A1EWFT6904 .C1EWFT6874 B1EWFT6864 C1EWFT6876 B1EWFT6866 CIEWFT6906 II-38

e l TABLE II-7 L -

INSTRUMENTATION INSPECTION DEFICIENCIES

,

-Field Sketch Instrument Findines IC-EW-12, Rev. 2 A1EWFT6856 1. Har.ger C welded at one end onl Drawing 4201-9-2-45080 Sheet 126,

, Detail A requires both ends welde . Hanger A not installed in accordance with the correct drawing detai IC-EW-10, Rev. 3 C1EWFT6906 1. Seven dimensions outside'of tolerance.

'

2. Sketch identifies instruments as FT-9606 and FI-960 . Loose conduit fittings at FT-690 . Inspected and accepted to ICEW-10, Rev. O. Rev. 3 in effect at time of inspectio IC-EW-02, Rev. 3 A1EWFT6904 1. Two dimensions outside of toleranc . Loose conduit fitting at FT-690 . Inspected and accepted to IC-EW-02, Rev. Rev. 2 in affect at time of inspection.

! IC-EW-09, Rev. 3 C1EWFT6874 1. Missing clamp east of hanger i 2. Hanger E 17 inches east of sketch location.

l 3. Hangers A and B attached to existing

'

.

support without required engineering concurrenc . Inspected and accepted to IC-EW-09,

, Rev. Rev. 3 was in effect at time of inspectio IC-EW-03, Rev. 3 A1EWFT6854 1. Conduit fittings loose at FT-685 . Flow transmitter loose at base plat . One dimension outside of tolerance.

,

IC-EW-04, Rev. 2 C1EWFT6873 1. Five dimensions outside of toleranc IC-EW-05, Rev. 2 B1EWFT6864 1. Hanger B attached to existing support i

without required engineering concurrenc . Conduit fitting loose at FT-686 IC-CC-22, Rev. 5 CICGFT4522 1. Three dimensions outside of tolerance.

I II-39

~III. MECHANICAL CONSTRUCTION Objective The~ objective of the appraisal of mechanical construction was to determine if the installed and Quality Control (QC) accepted mechanical items conformed to engineering design, regulatory requirements and licensee commitment 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 arec. In addition, certain programs, procedures'and documentation were reviewed as required to support or clarify hardware inspection finding . Piping Inspection Scope Piping depicted on the sixteen Bechtel isometric drawings listed in Tabe III-1 was inspected by the NRC CA Approximately 140 feet of 2 inch diameter and smaller. piping, and approximately 1680 feet of greater than 2 inch diameter piping, which had previously been accepted by Ebasco QC, was inspecte The inspection sample included piping located in the Unit 1 Reactor Containment Building (RCB), the Mechanical and Electrical Auxiliary Building (MEAB), the Fuel Handling Building (FHB), and the Diesel Generator Building (DGB); the~ Unit 2 MEAB; and the Essential Cooling Water structur Piping sizes ranged from 3/4 inch to 30 inches and pipe classifi-cations were ASME 1, 2 and 3. Attributes inspected included configuration (component orientation and dimensions), component locations and types, valve operator orientations, clearances, flanged joints (gasketing, bolting material, proper makeup), and hydrostatic testing. In addition, site construction practices were observ.e As identified in Table III-1,'six of the piping isometrics included in the NRC CAT inspection sample had been walked down for turnover to the Houston Light and Power (HL&P) Startup organization, for flushing and hydro-testing in accordance with Ebasco Quality Control Procedures (QCP) 10.14. One piping isometric included piping which had been hydrostatically tested. The h3 Jro-test documentation package was also reviewe Verification of installations in accordance with current design change documents were also selectively examined for the sixteen piping isometric drawings, involving 28 design change documents including Design Change Notices (DCN), Field Change Notices (FCN),

and Field Change Requests (FCR), as listed by Section VII, Table VII-7 III-1

The NRC CAT inspectors reviewed, and discussed with responsible inspectors and engineers the execution of the following procedures related to final walkdown inspections and engineering reconciliation of as-built conditions, developed to meet the requirements of IE Bulletin 79-14, " Seismic Analysis for As-Built Safety-Related Piping Systems."

Ebasco QCP-10.14, Rev. 3, " System / Subsystem Walkdown Inspection" Standard Site Procedure (SSP) -34, Rev. 0, " Technical Requirements and Walkdown Procedure for As-Building of Piping Systems"

-SSP-39, Rev. 0, " Engineering Procedure for As-Built Reconciliation of Safety-Related Piping Systems and Associated Pipe Supports" The following documents provided the acceptance criteria and background .information for the NRC ' CAT inspection:

Bechtel Specification, 5A010PS002, Rev. 7, " Piping Erection and Field Fabrication" Bechtel Specification, SL019PS004, Rev. 8, " Criteria for Piping Design" Bechtel Specification, 4UO10PS007, Rev. 6, " Pre-service and In-Service Inspection" Ebasco Construction Site Procedure, CSP-16, Rev. 5, " Piping Installation Procedure"

.

• Ebasco Construction Site Procedure, CSP-17,'Rev. 4, " Hydrostatic and Pneumatic Testing" Ebasco Construction Site Procedure, CSP-22, Rev.~3, " Valve / Pump Work"

• Ebasco Quality Control Procedure, QCP-9.1, Rev. 6, " Weld Inspection ASME" Ebasco Quality Control Procedtre, QCP-10.11, Rev. 5, " Mechanical Equipment Installation Inspection" Ebasco Quality Control Procedure, QCP-10.14, Rev. 3,

" System / Subsystem Walkdown Inspection" Ebasco Quality Control. Procedure, QCP-11.1, Rev. 4, " Hydrostatic and Pneumatic Pressure Test Inspection" In addition. the NRC CAT inspection included observation of the modificatio, of Unit 1 Reactor Coolant Piping by Westinghouse Construction in accordance with Westinghouse traveller T-TGX-05 This modification involving Fast Response RTD's was accomplished under a Westinghouse Field Change Notice (FCN).

III-2

e Inspection Findings NRC CAT inspections associated with specific piping isometric drawings are listed in. Table III-1. In general, piping conformed to design aid procedural requirements. However, several deficiencies were identifie On six lugged wafer valves. in the Unit 1 Essential Cooling Water System (EW-0016, 0019, 0052, 0055, 0089, and 0092), the hex-head cap screws in the flange-to-valve joints were determined through ultrasonic testing (UT) to be shorter than required by the asso -

ciated isometric-drawing and bill of materials, reducing thread engagement in several locations to less than one-half bolt diamete Licensee and NRC CAT inspectors subsequently performed a physical verification for the six lugged wafer valves, resulting in a con-firmation of the UT findings. In a number of other installations of

~

this type of valve in Unit 1, hex-head cap screws have been substi-tuted for threaded studs and nuts, without appropriate changes to the isometric drawing and/or bill of materials. In addition, the applicable Ebasco inspection procedure, QCP-10.11, does not require verification or documentation of the length of headed bolts used in assembly of bolted flange connections. Thus, the bolt length in lugged wafer valves installed with hex-head cap screws (in place of studs) is currently indeterminate, and based on NRC CAT findings, are likely to be incorrect. A Nonconformance Report (NCR CM-03068)

was initiated to disposition the first valve found with unauthorized substitution of cap screws for studs. Standard. Deficiency Reports (SDR E-353 and -354) were initiated to evaluate the extent of the construction deficiency and the inspection procedure deficiency. A Deficiency Evaluation Report (DER 85-057) was also initiated to '

evaluate the reportability of this-deficienc Undersize socket weld fillets were found on twelve of the thirty QC accepted field welds on isometric 4C369PCV417, SH. A02 for 2 inch Schedule 160 pipe fittings. During the NRC CAT inspection, a Nonconformance Report (NCR CP-03139) was issued to disposition the undersize welds. This deficiency is discussed in more detail in Section IV of this repor Two Annubar flow probe mounting flanges on isometric 3M369 PEW 229 Sh. 18, were mislocated with respect to the distance from the pip outer wall, based on the installation dimensions supplied by the vendor. However, these probes were located within the field piping erection tolerances provided in Bechtel Specification 5A010PS00 There are 33 such installations in the Essential Cooling Water, Component Cooling Water, and Chilled Water Systems. After discus-sions between Bechtel and the vendor to determine the extent to which these tolerances could be relaxed, Nonconformance Reports (NCR SJ-3008 and -3111) were initiated to rework the seven Annubar mounting flanges which did not meet the relaxed installation tolerance. A Deficiency Evaluation Form (DEF 85-80) was initiated to determine if field installation tolerances may impact other unspecified installation tolerances for vendor supplied pipe mounted instrumentatio III-3

At several locations on the support columns for Unit 1 steam genera-tors, the NRC CAT inspection noted zero clearance to steel work platform supports. A Nonconformance Report NCR BC-03193 was initiated. In a number of locations, piping exhibited zero or very small (less than 1/2 inch) clearance to adjacent components and structures. A further discussion of this issue is contained in paragraph III.B.2.b belo The NRC CAT inspectors considered the procedures related to final system walkdown inspections and engineering reconciliation of as-built conditions to meet IE Bulletin 79-14 requirements, to be thorough and well written. Responsible personnel were knowledgeable of requirements and responsibilitie No prcblems were noted in the inspected hydro-test packages or in the implementation of design. change document Conclusions

' Piping was found generally to conform to design documents. However, the improper flange bolting on lugged wafer valves indicates impro-per documentation / control of hardware changes and inadequate proce-dures and inspection effort for bolted joint makeup. The Annubar flow probe installation criteria deficiency indicates a design error, which requires resolution by engineerin . Pipe Supports / Restraints Inspection Scope Thirty-two ASME Class 1, 2 and 3 supports / restraints which represented a variety of types, sizes, systems and locations were selected for detailed inspection. As a result of the licensee's Pre-CAT inspection performed earlier this year, the basic support /

restraint inspection program was revised and previously accepted hardware was subjected to a reinspection for many attributes. The ,

sample selected by the NRC CAT included ten that had been through l the reinspection program and 22 that had been QC accepted under the new inspection criteria. These supports / restraints were inspected for proper configuration, clearances, member size, location, weld size, fasteners, expansion anchor installation and damage. See Table III-2 for a listing of the inspection sample.

Documentation packages for five of the inspected supports /

l restraints were examined for completeness, accuracy, and conformance to procedural requirements. The Field implementation of seven Field Change Requests (FCRs), four Field Change Notices (FCNs) and one Nonconformance Report (NCR) applicable to the inspected hard-ware were also inspected. See Section VII, Table VII-7 Acceptance criteria for the above described inspections were contained in the following documents:

• Bechtel Construction Specification SL340JS1002, Rev. 7, SCN 24, " Pipe Support Field Fabrication and Installation" III-4 t

• Ebasco Construction Site Procedure (CSP) 7, Rev. 5, ICP 4, " Pipe Support Installation"

• Bechtel Work Plan Procedure / Quality Control Instruction (WPP/QCI)

23, Rev. 6, " Fabrication and Furnishing Pipe Support Items" Ebasco Quality Control Procedure (QCP) 10.12, Rev. 4, " Component Support Fabrication and Installation Inspection"

• Applicable design drawings and change documents Inspection Findings At the time of the CAT inspection, of the approximately 9,000 ASME pipe supports / restraints to~be installed in Unit 1 and common systems, approximately 1200 had been QC accepted. Approximately 500 had been accepted under the revised inspection program and 700 had been previously accepted and reinspected to the new criteria by retrained inspectors. A review'of the licensee's Pre-CAT inspection report indicated a thorough study of pipe supports /

restraints. Improvements in specifications, procedures and person-nel training were implemented and reinspections performed as require Discrepancies were noted on seven of the 32 supports / restraints inspected by the NRC CAT. Discrepancies included out of tolerance angularity of a strut and a restraint brace member, undersized /

missing welds (two supports), undersized U-strap restraint, improper expansion anchor embedment and an oversized spacer plate installed that could have decreased support capacity. With the exception of the undersized U-strap, the discrepancies were not a major concern from a structural integrity standpoint although they were items.that should have been identified by QC during the inspection / reinspection process. In addition,- conditions were noted on several installa-tions relating to unclear criteria and/or work contro Restraint SI-9106-HL5009 consisted of a pipe clamp with welded lugs restraining the pipe laterally in a box frame. However, the ears of the pipe clamp were only about 3/8 inch from the horizontal members of the box frame. The construction specification allowed a 1/2 inch tolerance on clearances in the unrestrained direction. As no clearance in the unrestrained direction was specified on this drawing, it was not clear what was acceptable in this situatio The following actions were taken as a result of the NRC CAT inspec-tion findings: A change to the specification was issued to provide a tolerance on the installation of the pipe clamp for this type of configuration; a drawing review by engineering identified 47 restraints of this design including 11 that could still have potential interference due to thermal or seismic movement (including

.four that had previously been QC accepted); nonconformance reports were issued to provide for reinspection of the four supports and Design Change Notices (DCNs) were issued to specify the necessary clearance on the remaining seve III-5

.

A temporary hanger for a 30 inch pipe had been welded to support EW-9406-HL500 Although the installation of this temporary support was specified on a Request for Conditional Release form and a Startup Work Request (SWR), the only reference to removal was a note on the installation sketch. The NRC CAT inspectors consider that a more formal method of control is warranted with at least an inspection signature that the temporary support has been remove ~The inspector notes that this is a programmatic issue and that in this case the temporary support would most likely have been removed and system walkdowns should identify ~this type of oversight if left installe A large number of potential or actual interferences u e observe during inspection by the NRC CAT, between piping, supports /

restraints and other hardware, and installation and inspection criteria for this attribute did not appear to be adequate. It was determined that this issue had been identified months earlier by an INPO evaluation and had been reported to Region IV pursuant to 10 CFR 50.55(e). Although a program to address this concern has been developed, it has not yet been' implemented. More aggressive and timely action to provide craft and QC with acceptance criteria is warrante After identification of the undersize (under capacity) U-strap on restraint SI-9118-HL5009 the NRC CAT inspector selected and examined ten additional restraints that had heavy duty U-straps specified on the drawing. All were found to have the correct material installe The NRC CAT inspector noted two large (1500 pounds each) air operated valves on a three inch diameter Safety Injection line (SI-1117) in a high traffic area that were not supported, were visibly leaning and could easily be moved by hand. This was questioned by the inspector. Although not considered required by Bechtel site engineering, temporary supports were installed on these valve operators and installation of the permanent' designed supports was initiate The change documents associated with the supports / restraints inspected had all been properly implemented and closed ou No problems were noted in the documentation packages reviewe See Table III-3 for a summary of inspection observation c. Conclusions In general, pipe support / restraints were found to be installed in accordance with drawing, design change and procedural requirement However, due to the one undersized U-strap and number of other discrepancies noted, it appears that further improvement by craft and QC in attention to detail is required. Also, improved controls for the installation and removal of temporary supports is warrante III-6

. . . -. Concrete Expansion Anchors Inspection Scope Fifty-six concrete expansion anchors (CEAs) on 12 pipe supportshestraints and 97 CEAs on 17 HVAC supports were inspected in detai Inspection attributes included length, marking, embedment, spacing, edge distance, damage, angularity and residual torque. In addition, the CEAs on pipe' supports were verified to be the proper length by ultrasonic testing (UT). Various systems, sizes, and locations were included in the anchor sample. Table III-4 provides a listing of the anchors inspected. Anchors were torqued to the designer specified test torques which were 70% of minimum installation torque Seven FCRs, four NCRs and one DCN related to expansion anchors were inspected for conformance to as-built condition See Section VII, Table VII-7 Acceptance criteria for these field inspections were contained in the following. documents:

Bechtel Construction Specification 5A010SS1000, Rev. 7,

" Installation of Expansion Anchors, Rock Bolts, Grouted Anchor Bolts, and Core Drilling" Bechtel Construction Specification SL340JS1002, " Pipe Support Field Fabrication and Installation"

"

. * Ebasco CSP-41, Rev. 6, " Installation of Expansion Type Anchors" -

• Ebasco CQP 10.19, Rev. 7, " Inspection of Anchoring Devices Installed Within Concrete Structures"

"

Applicable design drawings and change documents Inspection Findings Nut rotation at test torque or less was observed on approximately 20 of the 153 CEAs tested and most turned very close to the test torque value. Only one anchor took as much a one turn to achieve minimum installation torque. Only one anchor was determined to have less than the specified embedment (on pipe-support EW-1329-HL5001) although many were at the exact minimum and many had been previously identified by QC as not meeting original specifications and were dispositioned by FCR or NCR. During the NRC CAT's inspection of pipe supports / restraints and mechanical equipment several cases of CEAs with out of tolerance embedment and anchor to concrete edge distances were identified. Other attri-butes were within design tolerances or had been previously identi-

, fied and dispositioned by engineering. The FCRs, NCRs and DCNs were verified as being acceptably implemented.

l III-7

-_

See Section-V.B.4.b (Civil / Structural) for a discussion of qualifi-cation testing and other design aspects of the concrete expansion anchor program at ST Conclusions Generally with the exception ~of minor deficiencies as noted above, the

-

concrete expansion anchors for pipe supports / restraints and HVAC supports were installed and inspected in accordance with design and procedural requirement . Mechanical Equipment Inspection Scope Twelve pieces of mechanical equipment including six HVAC mechanical components which are part of the STP's equipment specification, five ASME pumps, and one ASME tank were inspected for conformance to design and procedural requirement In addition the insertion of a Roto-lock reactor vessel stud insert (#35) in the Unit I vessel was observe The installation documentation for the inspected equipment was examined and the process control and QC verification documentation for assembly of the Unit I reactor vessel upper internals by Westinghouse Construction was also reviewe Table III-5 provides a listing of the mechanical equipment inspection sampl The following documents provided the acceptance criteria and background information for the NRC CAT inspection:

Bechtel Specification 4C1195S1008, Rev. 2, " Reactor Coolant System Component Supports and Other NF Steel Items"

• Ebasco CSP-22, Rev. 3, ICP-1, " Valve / Pump Work"

• Ebasco CSP-2, Rev. 4, ICP-5, " Installation of Permanent Electrical and Mechanical Plant Equipment" Ebasco SSP-24, Rev. O, " Disassembly / Reassembly of Safety and Non-Safety Related Valves" Ebasco QCP-10.11, Rev. 4, PCR-5, " Mechanical Equipment Installation Inspection" Ebasco QCP-9.1, Rev. 6, " Weld Inspection ASME"

• Bechtel Drawing 3A01-0-C-0010, " Concrete Standard Details-Embedded Plates-Misc. Supports"

• Bechtel Drawing 3A01-0-C-0012, " Concrete Standard Details-Embedded Plates-Misc. Supports"

• Applicable design drawings, vendor technical manual and drawings.

l

[

III-8 1 Inspection Findings Discrepancies were noted on most of the mechanical equipment installations examined by.the NRC CAT inspectors. Programmatic /

procedural weaknesses as well as inadequate QC inspection are of concer The discrepancies listed below were noted in the reassembly of the following Unit 1 pumps; Containment Spray (CS) pump B, Low Head Safety In.jection (LHSI) pump B, and High Head Safety Injection (HHSI) pump 8:

• Fasteners installed for bolting the motor stand to the motor and the motor stand to the foundation were of various material types or were unmarked. Washers specified for the motor stand to motor connections were missing. These installations had been accepted by QC and the joints sealed with " torque seal". Refer to Section VI, Material Traceabil'ty and Control, for further discussion of this concer Although the process control sheet referred to the vendor manual, which required installation of new 0-rings, the old 0-rings were reinstalle Although the applicable construction procedure, CSP-22, requires bagging of fasteners and small parts, disassembled fasteners -from the pump-motor couplings were observed stacked on the pumps and pump flange fasteners were observed scattered on the floor, and the QC inspector involved with the pump work was unaware of the bagging requiremen Discrepancies noted on four of the six mechanical equipment HVAC components inspected, included missing and undersize welds, unshimmed foundations, backed off foundation mounting nuts, improper concrete expansion anchor embedment and spacing to concrete cored holes, attachment welding to edge of embedment in possible violation of structural drawing requirements, damage, and support bracing that did not conform dimensionally to design. The current site program for inspecting non-ASME equipment does not provide for inspection of equipment support configuration dimensions etc. Based on a review of structural drawings 3A01-0-C-0010 and 3A01-0-C-0012 and discus-sions with pipe support and mechanical equipment QC inspectors it was apparent that the design requirements for welding near the edge of embedded plates was not clearly delineated. Site engineering

. committed to evaluation of existing criteria and revising drawings and retraining inspectors as require On the Reactor Water Make-up Tank the NRC CAT inspectors found that a design specified ring of cushion material (Flexcell) had been removed after QC acceptance of the tank installation. The tank mounting flange was in contact with the concrete floor at some locations and had more than a one inch gap at others. At the time of the inspection the tank was partially filled with water for flushing operations. The licensee was unable to provide evidence that formal documentation and/or controls existed to identify, III-9

track and restore the installation of the tank to design require-ments. At the request of the NRC CAT inspectors the licensee agreed to perform the following actions:

• Determine the nature and distribution of the remaining cushion material and other sandy material under the tan Evaluate the activities related to removal (and eventual replacement) of the cushion materia * Evaluate the stresses imposed on the tank due to loading the tank with the existing gaps around the foundatio During the NRC CAT inspection of piping it_was noted that vendor assembled piping spool flanges on Diesel Generator 1A had been disconnected, apparently to facilitate the installation of an adjacent field installed expansion joint. There was no documenta-tion authorizing this disassembly as required per QCP 10.27. During t

the course of this inspection these joints were remade, apparently to eliminate leakage during testing, again without authorization or control / documentation of proper joint makeu A Procedure Violation Notification (M-17) was initiated to address this proble During the observation of the installation of the Roto-lock insert, it was observea that a case of Molycote 505 anti-seize lubricant, which is no longer recommende~d by Westinghouse for nuclear-applications (Westinghouse letter DL-82-01 and WCAP-9464, 1979),

had been requisitioned and delivered to the reactor vessel flanga area. However, Ebasco personnel did use a recommended lubricant and the 1%tAe :etete rmined unopened. The Molycote was removed and NCR BN-03021 was initiated. The Inspectors note that the installation traveler for the RHR pumps listed as an acceptable lubricant FEL PRO N1000, whic- is . iso on the Westinghouse "not recommended" list. Again a .aeck of installation records indicated that an approved lubricant 'nd been used on the RHR pump However, it appears that additional .ittention to ensure control and use of approved lubricants is we rante On RHR pumps A and C, the construction process sheet (CPS) specifies as sequencing step 1 the installation of the pump supports per the vendor manual and drawing 3C01-9-S-1600. This is checked in the CPS column for " work sequence installation" as a prerequisite step to pump and motor installation. A QC HOLD point was not specific Subsequent steps of the CPS had been completed including machin.ng and leveling of the pump feet and support pads to a precise.0.00z inch tolerance. However, the ASME Equipment Support Checklist used in conjunction with the CPS, indicated that the torquing of the pump support foundation bolts had not yet been performed. The condition was considered acceptable based on the engineering response that the pump had not been accepted for levelness and location, nor had the pump alignment been performed. However, as the RHR pump instal-lation is still in progress, it appears that specific sequence requirements of the CPS should have been more clearly controlled with the review of exceptions taken to an intended prerequisite appropriately documented prior to completing subsequent work steps to III-10

<

ensure that leveling during subsequent torquing of foundation bolting is not degrade It should be noted that the installation of the lugged wafer valves with the fastener control problems previously discussed in the piping section of this report was under the control of the mechanical equipment installation program and the valves were inspected by mechanical equipment inspector No problems were identified during the review of reactor vessel upper internal installation documentatio Table III-5 provides a number of NRC CAT observations for the mechanical equipment items inspecte c. Conclusions Significant deficiencies were noted in regard to mechanical equipment installation. A lack of attention to detail by craft and QC inspators was apparent. Programmatic / procedural weaknesses regarding control and documentation of bolting activities, lubri-cants, inspection of non-ASME equipment support framework, and acceptance criteria for location of attachments to embedded plates was also apparen Licensee action is necessary in areas of mechanical equipment installation to provide assurance'that hardware is installed and inspected in accordance with design and procedural requirement Subsequent rework activities must be controlled, documented and provide for QC reverification of hardware acceptabilit . Heating, Ventilating and Air Conditioning (HVAC)

a. Inspection Scope Fifteen HVAC seismic supports / restraints, forty-seven duct sections, and five fire-dampers were selected from both Units 1 and 2 at random and inspected in detai The supports / restraints were inspected for location, configuration, member size, weld size and connection details. Duct sections and fire dampers were examined for proper configuration, companion angle size, joint make-up and free operation of fire damper In addition, adjacent HVAC hardware, including approximately 20 other HVAC supports / restraints, 25 duct sections, and 10 dampers was observed at random for the following attributes: loose or missing fasteners, joint makeup, improper clearances or angularity, disassembled, and damaged item Ten Field Change Requests (FCR) associated with the NRC CAT HVAC hardware samples were verified for conformance to as-built conditions. Also, twenty-four construction traveler packages were reviewed for completeness and accurac III-11

Acceptance criteria for these field inspections were contained in the following documents:

Bechtel Specification SV279VS1003, Rev. 5. " Installation of Safety Class and Non-Safety Class HVAC Equipment and Duct Work."

Bechtel Specification 3V279VS1000, Rev. 8, " Safety Class HVAC Duct-Work Fabrication."~

Ebasco Procedure CSP-6, Rev. 4, " Installation of HVAC Duct Hangers and Equipment klangers."

Ebasco Procedure CSP-9, Rev. 4, " Inspection of Duct and Duct Accessories."

Ebasco Procedure CSP-95, Rev. 2, " General Welding Requirements for HVAC."

Bechtel Procedure QCP-10.21, Rev. 5, "HVAC/ DUCT / HANGER Installation Inspection."

pplicable Duct Support / Restraint and Layout Drawing Inspection Findings Approximately 39 percent of the seismic supports, 22 percent of the duct sections, and 9 percent of the fire dampers had been QC accepted by Ebasco at the time of the NRC CAT inspection. During the inspection by the NRC CAT, workmanship appeared to~be good and no installation deficiencies were found for HVAC hardware (supports,

. duct sections, and fire dampers). However, during the observation of adjacent HVAC hardware, QC accepted tornado damper number 3V11V0A0302 was'found installed upside down. This apparent isolated case of questionable. installation was subsequently dispositioned

"use-as-is" by Bechtel Engineering on NCR BH-0303 Ten " Field Change Requests" (FCR) associated with the HVAC hardware inspected were reviewed and found to conform to the as-built condi-tio See Section VII, Table VII-7 The NRC CAT was informed of an reinspection program under

" Deficiency Evaluation Report (DER 85-031) conducted by Ebasco QC for direct attachment welds and expansion anchor bolt / base plate installation. During the inspection of HVAC supports the NRC CAT did not observe weld attachment discrepancies as described in DER-03 Six of the twenty-four " construction traveler packages" reviewed by

,

the NRC CAT for completeness and accuracy, were noted to have documentation omissions on the " Construction Cover Sheet" (Form

'

CS-AD-852). A Standard Deficiency Report (SDR) was subsequently issued by the licensee to Construction (SDR E-350) and to Quality Control (SDR E-351) to prevent the recurrence of these deficien-cies.

.

! III-12

- . Conclusions

.HVAC safety related support / restraints, duct sections, and fire

.

, dampers conformed to design and procedural requirement More attention to the review of documentation is required to ensure completeness and accuracy of the construction traveler package ,

4 ,

i i '

.

!

i I

,

III-13

TABLE III-1 PIPING IhSPECTION SAMPLE AND OBSERVATIONS Isometric Diameter (Note 1) (Inches) Class Notes Observations 2C369PAF402 6, 8 2 None

.Sh. 01, Rev. 3

~2C369PCV417 4 2 -

Clearance to hanger Sh. 03, Rev. 2 2M369PRH259 8 2 2, 4 Deficient ISI prep (NCR Sh. 02, Rev. 2- SP-03152)

3M369 PEW 229 . 6, 8 3 2, 4 Annubar flow probe mounting Sh. 18, Rev. 0 10, 30 flange (NCR SJ-03008 & 03111)

3M369PRM263 4, 6 3 2, 4 Broken flex conduit Sh. 03, Rev. 4 (SWR-01921)

3Y361 PEW 729 3, 24, 30 3 2 None Sh. 03, Rev. 3 4C369PCV417' 2 2 4 Undersize socket welds (NCR SH. A02, Rev. 4 CP-03139, SDR E-349 DER 85-049)

4C369PCC407 16 2 2, 4 Luggedwafervalvebbiting(NCR SH. 34, Rev. 3 NCR CM-03068, SDR E-353

& -354, DER 85-057)

Uncapped MOV housin (Main-tenance Discrepancy MD 1-0868)

4C369PRC457 3/4, 2 1, 2 -

Only partially inspected SH. A06, Rev. 4 during CA Reviewed hydro-test record /32" saw-cut in coupling 4C369PRH459 4, 12 1, 2 -

Masking tape on pipe.

Sh. 04, Rev. 6 Uncapped opening SD369 PEW 329 4, 6, 10 3 2 Broken temperature probe.

Sh. 01, Rev. 1 SD369 PEW 329 4, 6, 10 3 4 Valve reversed and handle Sh. 03, Rev. 1 blocked (NCR SP-03148)

III-14

_ - _ - _ _ _ _ _ .

_ _ _ _ . _____ __ __ - -

.

TABLE III-1 - (Continued)

PIPING INSPECTION SAMPLE AND OBSERVATIONS-Isometric Diameter (Note 1)- (Inches) Class Notes Observations SD369 PEW 329 4, 10 3 -

Clearance to support SH._04, Rev. 1 Wood blocking 50369 PEW 329 4, 6, 10 3 -

.Non SH. 06, Rev. 1 SF369PFC530 4, 10, 20 3 -

None SH. 04, Rev. 4 5M369PCC207 14, 20 3 3 No gaskets on temporary Sh. 10, Rev. 4 flange assembly (poor construction practice)

Notes Letter in second position of isometric drawing number identifies pipe locatio "

C = RCB M = MEAB Y.= Yard (Essential Cooling Water Intake Building)

2 0 = DGB '

F = FH . This isometric had been walked-down in accordance with Ebasco QCP-10.14, and turned over to HL&P Startup for flushing and hydro-testin . All isometrics are Unit 1 except SM369PCC207 HL&P and Ebasco discrepancy reports are a result of NRC CAT observations and are shown in parentheses ( ).

III-15

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

7_

TA8LE III-2-PIPE SUPPORT / RESTRAINT' INSPECTION SAMPLE Support / Restraint .

ASME Number M (Inches)- Location (1) Class

.RH-9215-HL5004 (2)- Strut 8 C 2-SI-9105-RR0031 (2) Strut 8 C 2 CC-9105-HL5007 (2)- Strut 16 C 3 SI-9106-HL5009 (2) Box 6 C 2

.

SI-9105-RR0038 (2) Box 8 C 2 RH-9206-HL5006 (2) ' Strut 8 C 2 RH-9102-SH0001(2) Spring 12 C 2 CC-9426-SH0001 Spri FHB 3 SI-9102-RH0007 Strut 8 FHB 2 CC-9427-HL5005 Strut 12 FHB 3 CC-9427-HL5004 Strut 12 FHB 3 EW-9406-HL5001 (3) Strap 3 EWPH 3 SI-9102-HL5001 Strut 8 FHB 2 EW-9113-HS5001.(3) Anchor 2 MAB 3 EW-9383-HL5001 (3) Box 10 MAB 3 EW-9283-HL5001 Box 10 MAB 3 SI-9117-RR0004 Strut 3 MAB 2 SI-9118-HL5009 (3) Strap 6 MAB 2 EW-9102-HL5001 Strut 30 MAB 3 EW-9205-HL5008 Strut 4 MAB 3 EW-9102-HL5003 (3) Strut 30 MAB 3 EW-9202-HL5001 Strut 30 MAB 3 RH-9205-HL5011 Box 8 MAB ' 2 RH-9205-HL5001 Box 8 MAB 2 SI-9118-RH0011 Strap 6 MAB 2 III-16

_ _ _ _ _

e

! -TABLE III-2 - (Continued)

PIPE SUPPORT / RESTRAINT INSPECTION SAMPLE Support / Restraint ASME Number Type (Inches) location (1) Class RH-9205-HL5009 Box 8 'MAB 2 CH-9203-HL5004 (2) Box 6 EAB 3 SI-9337-HF5005 (2) U-Bolt 2 FHB '2 CV-9032-H15015 (2) Box 4 MAB 3 l CC-9413-GU1004 Unit 2 Strap 4 MAB 3 CC-9413-HL5002 Unit 2 Strap 4 MAB 3 SI-9201-HL5009 . Strut 12 FHB 2 NOTES:

, (1) C = Containment Bldg.

!

'FHB = Fuel Handling Bld EWPH = Essential Service Water Pump House MAB = Mechanical Auxiliary Bld ,

EAB = Electrical Auxiliary Bld (2) Through licensee reinspection program l (3)' Document package reviewed l

I l

i

!

III-17

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

y TABLE III-3 PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS Support / Restraint Observations (1)

SI-9105-RR031 Strut angularity exceeds tolerance by 4 degrees (NCR CS-3181)

SI-9106-HL5009 Minimal clearance between pipe attachment and support structure in unrestrained direction (NCR CS-03314)

~ SI-9105-RR0038 Undersize skewed fillet welds (NCR CS-00875)

RH-9102-SH001 1/2. inch clearance to adjacent support'

EW-9406-HL5001 Temporary support attached SI-9118-HL5009 undersize U-strap installed (NCS CS-3189)

EW-9102-HL5003 Three expansion anchors with less than specified embedment (NCR CS-3182)

EW-9202-HL5001 Oversized plate installed but not properl documented / evaluate (NCR 55-3227)

CC-9413-HL5002 *

Missing flare bevel fillet cap weld (Unit 2) -(NCR CS-03263)

SI-9201-HL5009 Brace angle exceeds design' tolerance (NCR CS-03228)

NOTE:

(1) Ebasco NCR issued as a result of the NRC CAT observation (s) shown in parentheses.

f III-18

TABLE III-4 CONCRETE EXPANSION ANCHOR INSPECTION SAMPLE AND OBSERVATIONS Number / Diameter (Inches)

of Anchors Support / Restraint Inspected Observations Pipe S/R's:

CC-9318-HL5002 8 - 3/4 CC-1317-HL5006 4 - 1/2 CC-1317-RR13 4 - 3/4 CC-1114-GU19 4 - 3/4 CC-1317-HL5001 4 - 1 1/4 CC-1428-HL5016 4 - 3/4 CV-1006-HL5017 4-1 CC-9422-HL5005 4 - 3/4 CC-1414-HL5010 4 - 3/4 *(One CEA)

CC-1424-HL5004 4 - 3/4 CC-1301-HL5002 8-1 EW-1329-HL5001 4 - 1/2 Embedment violation on one CEA: 3 3/16 actual vs. 3 1/2 required (NCR SS-03264)

HVAC S/R's:

1-6-0144-5012 4 - 3/4 1-6-0144-S016 12 - 1/2 *(Four CEA's)

1-6-0144-5046 -

3 - 5/8 *(One CEA)

1-6-0144-5017 12 - 1/2 *(FourCEA's)

1-6-0144-5019 16 - 1/2 *(Eight CEA's)

1-6-0144-S037 4 - 3/4 1-6-065-5045 4 - 1/2, 4 - 1 1/4 III-19

- - - - _ - - _ _

7_ _

.. ..

-

TABLE III-4 --(Continued)

CONCRETE EXPANSION ANCHOR INSPECTION SAMPLE AND OBSERVATIONS Number / Diameter (Inches)

of Anchors Support / Restraint Inspected Observations HVAC S/Rs: I 1-6-0065-5025 4 - 5/8 1-6-0065-5075 4 - 3/4, 3 - 1 1-6-065-S008' 2 - 3/4, 2 - 1 *(One CEA)

1-6-0144-5083 6 - 1 1/4 1-6-0128-5083 8 - 1/2, 4 - 1 1/4 *(Two CEA's)

1-6-0128-5002 2 - 3/4 1-6-0128-S058 4 - 3/4 *(Two CEA's)

• Nut turned at or below torque value but minimum installation torque acbieved in less than 1 full additional turn of the nu ;

,

.

III-20

p--

'

TABLE III-5 MECHANICAL EQUIPMENT SAMPLE AND OBSERVATIONS Equipment (All Unit 1) Observations Reactor Water Makeup Tank Alteration to tank foundation configura-tion without proper documentation / contro Containment Spray Pump B Incorrect /indeterminant fastener materia Low Head Safety'Injecton Pump B ring reused when technical manual High Head Safety Injection Pump B specified replacemen . Fasteners not controlle RHR Pumps A and C Torquing of foundation bolts not completed

. prior to leveling and setup of critical support framin Charging Pump Supply Cooler- One mounting pad not shimmed as required 3V101VAH010 and damage to flange of foundation bea (NCR CM-03087).

EAB Return Air Fan-3V111VFN002 Gusset plate welded to edge of embed exceeding toleranc . Undersize attachment wel . Missing welds on 4 gusset plate . Damage frame member on fa . Notches in bracing not shown on drawin . Bolt hole locations in brace gusset plates'not per drawing. (NCR CM-3092)

Control Room Return Fan - None 3V111VFN026 MEAB HVAC Chiller - 3V111VCH001 None Charging Pump Supply Cooler - North end of attachment welds 1/16 to 3V101VAH004 1/8 inch undersize entire lengt . Attachment welds to edge of embed plate violates drawing requiremen . Two maxibolts to cored holes in concrete violate minimum spacing requirement (12 1/2 inch required, 5 inch actual) Nut is tight on foundation stud but is 1/4 inch from mating with contact surfac (NCR CM-03091)

i Fuel Handling Building Filter Undersize unit to embed fillet welds.

l Train-3V121VXV003 Expansion anchors violate minimum i spacing to cored hole . Expansion anchors do not have required embedment.

i r

NOTE: Ebasco NCR's generated as a result of the NRC CAT observation (s) shown in

, parenthesis.

l

,

III-21 l

I

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

,-

TABLE III-6 HVAC INSPECTION SAMPLES AND OBSERVATIONS (Supports / Restraints)

Inspection Support Duc ~FCR Traveler Number Size I Unit' Building 1 Review Reviewed Observation 1-1-0083-S014 8 di RCB None Yes None 1-1-0083-S039 16 di RCB BH-00827 Yes None 1-1-0083-5040 16 di RCB CH-01546 Yes None 1-1-0083-5046 8 di RCB BH-00559 Yes None 1-1-0083-5048 16 di RCB CH-00845 Yes None 1-1-0083-5049 16 di RCB None Yes None 1-1-0087-5-004 14x10 1 RCB CH-01800 Yes- None 1-6-0143-5016 30x72 1 EAB DL-00152W - Yes None 1-6-0144-5017 12x12 1 EAB CH-02181W Yes None 1-6-0144-5019 12x12 1 EAB EAB-314 Yes None 2-6-0050-S033 14x16 2 EAB None Yes Document discrepancies on content sheet of construction travele x20 2 EAB None Yes Document discrepancies on content sheet of construction travele .

III-22

._ _ _ _ ______ _ _ _ - ____-_ - _ ___- _ __ - __ _ - -_ _ _~

TABLE III-6 (Continued)

HVAC INSPECTION SAMPLES AND OBSERVATIONS (Supports / Restraints)

Inspection Support Duct FCR Traveler Number ' Size I Unit Building 1 Review Reviewed Observation 2-6-0124-5003 20x18 2 EAB None Yes Document i discrepancies on content sheet of construction travele S066 22x22 2 EAB None Yes Document discrepancies on content sheet of construction travele S005 20x18 2 EAB BH-01844 Yes Document discrepancies on cover sheet of construction travele 'RCB = Reactor Containment Building EAB = Electrical Auxiliary Building III-23

--

_ _ _ _ _ _ _ _ _

,

TABLE III-6 (Continued)

HVAC INSPECTION SAMPLES AND OBSERVATIONS (HVAC Sections)

Inspection-Orawing Number FCR Traveler

& Duct Sections Unit Building 1 Reviewed Reviewed Observations 5-V-14-1-V- 1 RCB None None None 0083-A-10 Rev. 5 HVAC Section No P-005 thru P-019 5-V-14-1-V- 1 RCB None None None 0083-B-1D Rev. 5 HVAC Section No P-101 thru P-114 5-V-11-1V- 1 EAB BH-01142 Yes None 0144-A-1D (P-011, Rev. 0 012, 015, HVAC Section No , 021, P-011 thru P-025, and P-025)

P-027, P-028 2RCB = Reactor Containment Building EAB = Electrical Auxiliary Building III-24

. -

TABLE III-6 (Continued)

HVAC INSPECTION SAMPLES AND OBSERVATIONS (Fire Dampers)

Inspection Drawing Fire Damper FCR Traveler Number Number Unit Building 1 Reviewed Reviewed Observations 5-V-11-1-V- FF-01 1 EAB None No None 065-A-ID, Rev. 4 FF-04 1 EAB None No None 5-V-11-1-V- FF-319 1 EAB None Yes None 0128-A-ID Rev. 3 FF-320 1 EAB None Yes None FF-321 1 EAB None Yes None IRCB = Reactor Containment Building EAB = Electrical Auxiliary Building

.

III-25

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

IV. WELDING AND NONDESTRUCTIVE EXAMINATION Objective The objective of the appraisal of welding and nondestructive examination (NDE) was to determine if Quality Control accepted work related to welding and NDE activities was controlled and performed in accordance with design requirements, Safety Analysis Report commitments, and applicable codes and specification An additional objective was to determine if personnel involved in welding and NDE activities were trained and qualified in accordance with established performance standards and applicable code requirement B. Discussion To accomplish the above objectives; welds and welding details for piping; pipe supports /retraints; field and shop fabricated tanks; structural steel installations; heating, ventilating and air condition-ing (HVAC) installations; electrical supports; and instrumentation control tubing and supports were inspected. The inspected welds were selected to provide a representative sample of the applicant's contractor welding activities in terms of welding processes used, materials welded and existing weld-joint configurations. Considera-tions such as physical location, difficulty of welding and limited accessibility were also used in sample selection. Design changes related to welding such as increase or decrease of weld sizes and a change from one welding process or procedure to another welding process or procedure were also reviewed for technical adequacy and implementatio NDE activities were appraised through the review of radiographs for both field and vendor fabricated welds, the review of NDE procedures and personnel qualifications, the inspection of the calibration status of NDE equipment and the witnessing of in process NDE activities. The NRC construction assessment team (CAT) inspectors reviewed a sample of radiographic film in final storage in the vault of the licensee's facilit In addition, a sample of NDE documentation was requested for review which was stored by the Nuclear Steam System Supplier, Westinghouse and was not yet transmitted to the license During the inspection of structural welds in the pipe supports' area, the NRC Construction Appraisal Team (CAT) identified welds which did not meet the weld size requirements specified by the Architect Engineer, Bechtel Power Corporation (Bechtel). Undersized socket welds were also identified in 2 inch schedule 160 piping spools. Some undersized weld reinforcements were also found in nozzle to shell joints (ASME Code Category D Joints) on tanks and heat exchangers. A detailed discussion concerning these welds is included later in this sectio In the area of NDE, the NRC CAT inspectors reviewed. film for field and shop fabricated pipe welds, film involving equipment and hardware supplied under the Westinghouse (NSSS) scope of supply and film supplied by various vendors and contractors for the balance of plan IV-1

.

!

l l

A relatively small number of deficiencies were found in the reviewed sample of radiographs. However, in the area of NDE documentation, with the exception of the Westinghouse file, the team encountered difficulties in establishing the number of NDE vendors and suppliers.

The inspectors also observed that in general the project has difficul-ties in identifying existence and location of film and documentation related to the balance of plant suppliers. For equipment and hardware supplied under the NSSS scope of supply the licensee has instituted a program in which, Westinghouse is required, to submit monthly reports identifying the current status of film and NDE documentation. The program was instituted in May 1985 after the project identified missing radiographs of the reactor head supplied by Combustion Engineering. The NRC CAT believes that some similar program is needed for the balance of plant suppliers, to insure film and documentation could be readily identified. A detailed discussion concerning NDE deficiencies, retrievability and availability of film and documentation is provided later in this section.

The welding and NDE activities were examined in order to ascertain compliance with the governing construction codes and specifications.

This effort involved the review and inspection of the following contractors:

Field Activities Bechtel Power Corporation: architect engineer. Ebasco Services Inc.: piping installation and piping supports /

restraints, fire protection system fabrication and installation, electrical, instrumentation, HVAC installation and structural steel erection. Pittsburgh Des Moines Corp. (PDM): containment liner and contain-ment penetration fabrication and installation, reactor and spent fuel liner fabrication. Westinghouse: reactor internals-modification and installation. Babcock and Wilcox: Steam Generator Eddy current preservice inspection and examinatio Shop Fabrication Southwest Fabricating & Welding Company, Inc.: shop fabricated piping spools. Copes-Vulcan: valve manufacturer. Westinghouse: nuclear steam supply system. Anchor / Darling Valve Company: valve manufacturer. Teledyne Brown: steam generator supports fabricato IV-2 Esco Corporation: material supplier. Sandansky F&M Company: material supplier. Brown Minneapolis Tank Manufacturers: tank fabricator. RECO industries: tank fabricators.

10. Fisher Controls: valve manufacturer.

11. Joseph Oat Corporation: heat exchanger manufacturer.

12.~TRW Mission Manufacturing Co.: material supplier.

13. Richmond Engineering: tank fabricators.

14. Pacific Pumps: pump manufacturer.

15. Pacific Valve: valve manufacturer.

16. Master Craftsman Inc.: ' heat exchangers suppliers.

17. Pall Trinity Micro. Corporation: cartridge filters supplier.

18. Lamco Industries: tank fabricators.

19. Quaker Ally Casting Co.: castings supplier.

20. Wollaston Alloys: material supplier.

21. McJunkih Corporation: material suppliers.

22. Combustion Engineering: reactor vessel fabricator.

23. Sabine Steel: tank fabricators.

24. GW Energy Product Corp.: tank fabricators.

25. Atlas Industrial manufacturing: heat exchangers manufacturer.

26. Struthers Wells Inc.: heat exchanger manufacturer.

27. PDM - tank fabricators.

The results of the inspection activities involving each of these areas and contractors are documented as follows:

IV-3

1. Pipe and Pipe Support Fabrication a. Inspection Scope (1) Welding Activities The NRC CAT inspectors reviewed activities relating to fabrica-tion contracts in the areas of piping system welds, support /.

restraint welds, welding procedures, welder qualifications, NDE procedures, personnel qualifications, and the review of radio-graphic film for shop and field fabricated welds. Field welding involving pipe fabrication was performed by Ebasc .

Southwest Fabricating and Welding supplied the shop fabricated piping spool The NRC CAT inspected 41 pipe supports / restraints involving approximately 450 welds to verify conformance of welding to drawing requirements, and to confirm the visual acceptability of welds. Thirty-four of the pipe supports had been inspected by QC inspectors, 4 supports were "in process" and were not yet inspected by QC, and 3 supports were identified as Class 7 supports which does not require QC inspection except on a random basis. The "in process" and Class 7 pipe supports were inspected in order to verify the initial quality of work performed by craft personnel. See Table IV-1 for a listing of supports subjected to detailed inspection. Additionally, another 14 supports / restraints involving 150 welds were-visually inspected to verify the quality of the completed weld See Table IV-2.for a listing of supports inspecte '

The NRC CAT inspectors also inspected the welds on the upper and lower lateral supports.for two steam generator The steam generator supports were fabricated by Teledyne Brow Three sets of Bechtel calculations for the design of skewed welded supports were also reviewed for adequac The NRC CAT inspection of piping welds consisted of visual inspection during walkdown of piping systems and inspection of pipe welds located near the supports restraints being inspecte Approximately 62 piping spools involving 1200 American Society of Mechanical Engineers (ASME) Class 1,.2 and 3 welds were inspected. Four of those piping spools were subjected to detailed inspection which included the review of pertinent QC documentation while the remaining 58 spools were only visually inspected. Both field and shop welds were inspected in order to assure compliance with the requirements of the ASME Coo See Tables IV-3 and IV-4 for listings of piping spools inspecte In addition, 60 welding filler metal test reports, 27 welder qualification test _ records and 6 welding procedures were reviewed for' compliance with applicable specifications, procedures and the ASME Code requirement IV-4

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

'

,

~

'

(2) Nondestructive Examination Activitie J-JThe NRC CAT inspection of NDE activities in the pipe fabri-cation area included the review of 46 shop and 145 field fabricated welds which involved 1,905' film. The-field welds were fabricated by Brown and Root (SR) and-Ebasco and the shop

fabricated pipe spools were supplied by Southwest Fabricating i and Welding. _In addition, 6 NDE procedures and 4 NDE personnel

' qualification records were reviewed in order to verify compli-

~

ance with the governing codes and specifications. Three NDE ,

I technicians were observed while performing in process inspec- '

tions and were evaluated for their ability to follow the .

,

applicable inspection procedures. Twenty pieces _of NDE equip- "

, ' ment were inspected for calibration and one NDE procedure wa reviewed for adequac ,

I

. Inspection Findings  !

(1) In general, the inspected pipe and pipe supports / restraints welding activities were found to comply with' governing codes and specifications. However, discrepancies were identified l involving undersized welds'in pipe supports / restraint Specifically, eight QC accepted skewed welds were found to b undersized and two other-skewed welds were located on the acute side of the joint instead of the obtuse side as required on the' '

drawin Ten nonskewed welds were also found to be undersized with~ respect to.the specified acceptance criteria. As a result

~

'of these findings-the licensee issued nonconformance reports and the deficient' welds will be reviewed and evaluated by~

Bechte ,

In the area of "in process"-and class 7 pipe supports inspec-

-tions, the NRC CAT inspectors also identified welds which did

not conformed to the specified acceptance criteria. Twelve

"in process" welds were found'to be undersized and two gusset

plates were missing in one of the inspected supports. 10 of

,

the inspected welds in class 7 supports were also found to be  ;

undersized. As a result of this finding Ebasco and HL&P indicated that they will conduct additional training for both  ;

L craft and inspection personne ;

,

One of the three sets of calculations reviewed for the design l of supports having skewed joints.did.not have any calculations

for the welds in the skewed connections. The calculations also did not provide compensation for the loss of weld throat ,

thickness in. skewed weld '

.

The lack of calculations for skewed joints had been previously-identified on a number of supports.during a third party design assessment performed in March and April 1985. The project'has committed to review the design calculation and such review was i underway during the time of the NRC CAT inspectio .I i

IV-5

-

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

Undersized reinforcing fillets on groove welds and undersize fillet welds were found on the upper and lower steam generator lateral supports. NRC CS-03201 was written against this finding. Ebasco performed additional inspection consisting of mapping out the undersized conditions, which were evaluated and accepted by Bechtel without rewor During the inspection of pipe welds the NRC cal inspectors identified undersized socket welds in 2 inch schedule 160 pipe spools. As a result of this finding the licensee issued NCR CP-03139. A Standard Deficiency Report (SDR E-349) was issued to determine the extent of the undersize condition in other small-bore socket welds, and a Deficiency Evaluation Report (DER 85-049) was issued to evaluate the reportability of the condition. Results of the reinspection conducted by Ebasco QC indicated that the undersized condition is limited to 2 inch Sch.160 socket welds fabricated in the field (not the site fabrication shop). Of the approximately 200 QC accepted field welds of this type, at least 15 percent were reported to be undersize. No undersized socket welds were found in other pipe schedules and sizes by the_NRC CAT inspectors or the Ebasco reinspection effort.

The NRC CAT inspectors also visually inspected ~55 socket welds for proper fitup and gap. In addition, 7 socket welds ~were radiographed to determine that the required gap exist between the pipe and the fitting. No discrepancies were identified during the visual and RT inspections. Two of the-100 inspected

" weld-o-let" pipe branch connections were found to have inade-~

quate weld sizes. NCR HP-3238 and NCR HP-03164 were written to document this condition.

During the review of Welding Procedure Specifications,_one of the supporting qualification records for WP-89 was found to violate ASME Code requirements regarding the size of tensile specimens which were in effect at the time the qualification tests were performed. Ebasco Welding Engineering performed a review of the applicable qualification record against current code requirements, which had deleted the tensile specimen restriction, and it was found acceptable.

During review of the Material Test Reports for welding filler metal, it was observed that the purchasing specifications and test reports did not specifically address the requirements of ASME Section III regarding the cooling rate of post weld heat treatment to be followed during welding of the test coupons.

Bechtel agreed to add the cooling rate requirements to the purchasing specification, as well as the specific tensile strength requirements for material tested in the heat treated condition. Based on review of 60 welding filler metal test reports, this discrepancy has no consequence on hardwar IV-6

(2) Nondestructive Examination Activities In general, the inspected NDE activities were found to comply with the applicable codes and specifications. No deficiencies were identified with the inspected shop fabricated pipe weld However, during the review of the radiographic film for field fabricated welds some deficiencies were identified which involved the following four welds:

• Weld EW 1202 - FW 0027 was found to have low weld thicknes * Weld EW 1205 - FW 14 had a linear. indication adjacent to a repair are * Weld EW 2205 - FW 0009 had a penetrameter shim extending into the area of interest; one repair-view indicated that the complete area repaired had not been covered; and one view exhibited porosity with a crack extending from_i NCR

1. BP-03221 was written to document this deficienc * During the review of circumferential weld C52007 - FWOO6 the adjacent area of the logitudinal weld seam showed a crack

.like indication in the seam. The licensee indicated that the crack like indication may be caused by microbiological induced corrosion (MIC) attack which has taken place during the storage of the pipe. The licensee committed to investi-gate further the cause and nature of this indicatio It should be noted that weld EW1202 - FW0027 and weld EW1205 -

FW14 identified above have been reviewed during HP&L audit

1. M11-301 of the radiographic activities prior to the NRC CAT inspectio The HP&L audit did not ideritify any deficiencies with those two welds which indicates that the audits were not effectiv See Section VIII'of this report for additional details concerning project audits and corrective actio~ns.

c. Conclusion (1) Welding Activities In general, the inspected welding activities were found to comply with the requirements of_the applicable codes and specifications. However, the NRC CAT found structural welds on pipe supports / restraints which did not meet the weld specifi-cations. Skewed connections did not meet drawing requirements

.for size and location and some were not supported by calculation In addition, undersized socket welds were found in 2 inch schedule 160 piping spool IV-7

. ..

(2) Nondestructive Examination In general, the inspected NDE~ activities were found to comply with the requirements of the governing codes and specifica-tions. However, the NRC CAT found some welds which had linear indications and another weld which had low weld thickness. In addition, the reviewed NDE audits were found to be ineffectiv . Reactor Internals Modification and Installation Inspection Scope Approximately 30 tack welds on the bottom mounted Instrumentation (BMI) locking caps were~ visually inspected. The documentation packages for the welds on the Core Barrel Assembly and tie plates for the lower internals were reviewed. The documentation package for the welds on the Energy Absorber Installation was also reviewe In addition, one welding procedure and the qualification test records for two welders were also reviewed for adequacy. The modification work was performed by Westinghous Inspection Findings and Conclusions No problems were identified in the area of irispected welding activities. Activities were found to meet the specified acceptance criteri . Preservice Inspection (PSI) Inspection Scope Approximately 30 steam generator tubes requiring preservice and inservice inspections were witnessed while performing Eddy current inspections in order to verify compliance with the requirements of Section XI of the ASME Cod In addition, the qualification test records for four Eddy current technicians were reviewed and 2 technicians were observed while performing Eddy current inspection The NDE procedure and 10 data records, were reviewed for adequac b. Inspection findings and Conclusions No problems were identified in the inspected preservice inspection activitie Activities were found to comply with the requirements of the governing codes and specification . Electrical Installation and Electrical Supports a. Inspectior Scope The NRC CAT inspected approximately 110 welds in the area of electrical installatio This involved the inspection of welds on 6 cable tray -supports, 2 junction ' box supports, 9 conduit supports and the installation welds for 3 electrical panels. Two welding procedures and the qualification test records for five welders were reviewe In addition, the personnel qualification test records for IV-8

_ _ . _ -

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

four welding inspectors were also reviewed and two inspectors were observed and evaluated for their ability to follow the visual I inspection procedure The welding activities in the electrical

'

area were performed by EBASCO. Inspection Findings During the inspection of Electrical supports 1-016-H99 and 1-016-H100 it was established that those supports were QC accepted-for integrity and tightness of technical connections on September 15, 1984. Since that date, two bolted connections on support H-100 have been changed to welded connections without obtaining the required Modification / Removal Form prior to installation of the welded connection As a result of this finding a Quality Control

. Notification of Procedural. Violation #C-8 was generated and the connections will be inspected by QC to determine the acceptability of the welded connections. Conclusions No major problems were identified in~the area of inspected welding activities. With the exception of the uncontrolled modification discrepancies, all inspected activities were found to comply with the applicable construction codes and specifications. Instrumentation Tubing Installation and Instrumentation Supports Inspection Scope Approximately 80 welds involving 10 instrumentatic.. supports were visually inspected to ascertain compliance with_the specified acceptance criteria. Two welding procedures and qualification test records for four welders were reviewed. The qualification records for five NDE inspectors were also reviewed. Two visual welding inspectors were observed and evaluated for their ability to follow the applicable inspection procedures. The radiographs for one instrumentation tubing weld was also reviewed for adequacy. The welding in the instrumentation area was performed by Ebasco. Inspection Findings During the review of documentation of instrument stand EWR~#A03134 it was discovered that the stand has been fabricated and installed without the welds being inspected as required by QC procedure QCP-95 paragraph 5.2.1. As a result of this finding the licensee issued NCR C503004. The paint was removed from the welded areas and the welds were inspected as required by the inspection procedures and no other problems were note During the inspection of supports.for instrument #N2ED-FT-7822A it was noted that a double type globe strut (G5812A strut) was used instead of.the required single type globe stru As a result of this finding Ebasco generated Deficiency Report (DR) I-0021 and all *

IV-9

double type globe strut (G-5812-A) will be removed. The construc- l tion personnel was instructed in the correct use of the G-5812-A ;

stru l

Conclusions No major problems were identified in the area of inspected welding activities. With the exception of the globe strut installation discrepancies, all inspected activities were found to comply with the applicable construction codes and specification . Heating, Ventilating and Air Conditioning Installation and Supports Inspection Scope Approximately 120. welds involving 16 supports were inspected for compliance with the specified acceptance criteria. Two welding procedures and the qualification test records for five welders were

~

reviewe In addition, four personnel qualification test records were also reviewed and two welding inspectors were observed and evaluated for their ability to follow the visual inspection procedure The welds on four duct pieces, two air blowers and two dampers were also included in this inspection. The welding in the HVAC area was performed by Ebasco. Inspection Findings and Conclusions No problems were identified in the area o.f inspected welding activi-ties. Activities were found to comply with the applicable construc-tion codes and specifications. Structural Steel Fabrication, Erection and Modification Inspection Scope Approximately 120 welds comprising 70 field and 50 shop welds involving 16 structural beams and columns.were visually inspected in order to ascertain compliance with the specified acceptance criteri Two welding procedures and the qualification test records for five -

welders were revie, se Visual inspection procedures and the quali-fication records for four inspectors were also reviewed. Four welding inspectors were observed and evaluated for their ability to follow the visual inspection procedures. The structural steel field welding was performed by Ebasc American Bridge Steel-Company supplied the structural steel to the project. Inspection Findings No problems were identified in the area of inspected field welding activities.- However, several original welds involving clip to beam web connection welds were found to be deficient. Specifically, the design drawings required fillet welds all around, while the connec-IV-10

. . . .

r tion was seal welded on the top and bottom of the cli As a result of this finding the licensee issued NCR #HC-03182, HC03183 and HC-03184. The welded connections were evaluated by Architect Engineer, accepted "as is" and determined to be adequate for the intended applicatio c. Conclusions In general, the . inspected welding activities were found to comply with the governing Code and Specifications. With the exception of the deficient undersized clip to web welds, which require engineering evaluation, the inspected welding activities were found to comply with the specified requirement . Refueling Cavity and Spent fuel pool Liner Fabrication a. Inspection Scope The NRC CAT visually inspected approximately 80 feet of welded seam on the spent fuel pool and the Reactor Pool Liner. The attachment welds for four brackets and the welds' on two erriedment plates were also inspected in order ~to ascertain compliance with the specified acceptance criteria. One welding procedure was also reviewed for adequac In the area of NDE, the NRC CAT reviewed the NDE docu-mentation for the required vacuum box testing of the inspected welds. The Refueling Cavity and spent fuel pool Liner fabrication was performed by PD b. Inspection and Findings and Conclusion No problems were identified in the areas of inspected welding and NDE activities. Activities were found.to comply with the applicable construction codes and specification . Containment Liner and Containment Penetration Installation a. Inspection Scope The NRC CAT visually inspected approximately 60 feet of liner seam, the welds on two incert plates, four welded plugs, the welds on one construction opening, and the attachment welds for two mechanical and two electrical penetrations. Two welding procedures and the qualification test records for four welders were also reviewe In the area of NDE, the NRC CAT reviewed the radiographs for 41 welded seams which involved 674 films. One radiographic examination procedure was also reviewed as a part of this inspectio The containment liner and penetrations were installed by PD b. Inspection Findings and Conclusions No problems were identified in the area of inspected welding and NDE activities. Activities were found to comply with the require-ments of the governing codes and specification IV-11

-10. LVendors-and Shop Fabricators Other Than Those Previously Addressed

- Inspection Scope

.The NRC CAT visually inspected nine vendor supplied tanks and heat exchangers. See Table IV-5 for inspected vendor supplied equipmen In addition to'the welds inspected and listed in Table IV-5, the NRC CAT inspectors reviewed radiographs related.to work performed by 25 vendors which have supplied various equipment and hardware to the South Texas Power-Station project. .A total of 2,271 feet'of welded-sean involving 3,168 radiographs and 20 welds involving 145 film were. reviewed. The radiographs for 74 valves, pumps and castings involving 1,170 film, and the radiographs-for 105 spot welds involving 105 film were also~ reviewed for compliance.with the

-

governingLcodes and specification Inspection Findings

-

During the inspection of tanks and heat exchanges supplied by the vendors-listed in.T%1e IV-5, the NRC CAT found that the size of the nozzle and manway weld reinforcement did not meet the require--

.ments stated in the' vendor drawings. In addition, the welds on some of the inspected supports-were also found to be undersized. A total of seven tanks an~d heat exchangers'were found to deviate from the required drawing sizes. See Table IV-5 for details. -The NRC has issued.Information Notice 85-33 on the subject of undersized weld reinforcement in ASME Code nozzle to shell joints. The project has not performed any. inspection of tanksLand heat exchangers prior to

-the NRC CAT inspection, indicating the licensee may not have performed an adequate review of the content.of this notice for applicability to the South Texas = sit In the area of NDE the NRC CAT inspectors identified disorganized reports, . linear indications and yellow film in radiographs and NDE documentation supplied by vendors. See Table IV-6 for detail Prior to the NRC CAT inspection the NRC requested that the project provide a list of. vendors which have supplied radiographs in conjunction with vendor supplied equipment and hardwar Such a list was still unavailable at the end of the first two weeks of the NRC CAT inspectio At the beginning of the second.two week period, film from several vendors picked at random was requested. This list included; Guyon Alloys, Rockwell, Lonergan, Target Rick, Valtek, Yarway, Clow, and Posi-Seal, among others. A computer search failed to locate any record of. film for these vendors. Furthermore, there appears to be no way to readily determine whether film is required or not required for these purchase orders. If the film is required for any of these orders, there seems to be no convenient method to determine where the. film is located, or even if it exist A document search for four of the above vendors was conducted using only one purchase order per vendor and the following results were obtained: Target Rock-P.O. 4050 included some 8 inch ASME III IV-12

.

valves which probably would require radiographs. Further search is~necessary to determine this. Valteck-0.0. 4409 includes many valves requiring weld end radiographs. A search for these radio-

-

graphs has been started by the applicant. Yarway-P.O. 6455 includes ASME III Valves which, if cast would require weld end radiograph Clow-P.O.6452, as above, if the valves are castings, weld end radiographs probably would be. require Early in the first week of the inspection the NRC CAT requested the radiographs for three Component Cooling Water (CCW) heat exchangers fabricated by Struthers Well In the third week another request was made for film based on P.O. No. 4018, FID NO. P0610 and PID N0 R201NMX101A, 3S201NMZ101B and 3R201NMX101C. The computer found no film. Also no information could be obtained as to whether the film existed or where it could be found. A document search.found that the film had been reviewed by the vendor, that verification of the review had been made, but no indication of a request for the film to be sent to the site was foun During the last two weeks much effort was expended to come up with a computer program which would expedite retrieval of information-concerning the radiography program. A program was developed that does improve accessibility of information concerning radiographs in the film storage vault. However, the ability to determine if a verdor should have performed radiography is still a tedious and time cons 1 ming tas After a brief scan of the vendor list the possibility that there could be in excess of 60 vendor purchase ordera that may require radiography and for which there is no program for expeditious retrieval of this informatio It should be noted that the Code of Federal Regulation 10 CFR 50 Appendix B, Criterion VII requires that documentary evidence that the material and equipment conform to the procurement requirements be available at the site prior to installation or use of the material and equipmen The documentary evidence is to be retained at the site and shal1 be sufficient to identify the specific requirements, such as codes, standards or specifications met by the purchased material and equipment. Since the NDE requirements are

<

specified by the ASME code, the NRC CAT team believes that the project should have instituted a program to identify location and

'

existence of NDE film and documentation for the Balance of Plant vendors and supplier ~

The NRC CAT also reviewed NDE documentation and film which was under the Westinghouse scope of supply and in general the retrievability and availability of NDE documentation was found to be satisfactor It should be noted that the project has instituted a program requiring Westinghouse to suomit monthly reports concerning status-and availability of NDE film and documentation. This program was instituted after missing radiographs were identified for the reactor vessel head. The NRC CAT inspectors believe that the project should have instituted the program to cover both, the Westinghouse i,

suppliers and the balance of plant suppliers so that the existence and location NDE film and documentation could be promptly identifie IV-13

.- _ -- - ._

-

c. Conclusions In general, the inspected welding and NDE activities'were found to comply with the requirements for the governing codes and specifi-cations. However, seven tanks and heat exchangers were found to deviate from the requirements stated in the applicable drawings and specification In the are of NDE, several radiographs and NDE documentation supplied by vendors were found to be deficient with respect to the_ required quality. In addition, difficulties were encountered in retrievability, availability and location of NDE film and documentation for the balance of plant suppliers which indicated that the licensee had performed inadequate corrective action after the discovery of missing radiographs for the reactor vessel head in May 198 The difficulties encountered in retrievability, availability and location of NDE film and documentation pertaining to the Balance of Plant Scope of supplied equipment, indicates a need for a formal program to identify requirements, location and existence of NDE film and documentatio IV-14

- --

_

.

TABLE IV-1 LIST OF SUPPORTS WHICH WERE INSPECTED AGAINST DRAWING REQUIREMENTS SA-1756-HF5025 (1) CC-1318-HL5002 'CC-1403-HL5001 FW-10160-HL5001- .CC-1402-RR3002 FW-1018HL5001 (4)

CC-1401-HL-5003 CS1001-RR0029 (2) .CC-1106-HL5016 CV-1209-RR002 (5) FP-1560-GUO412 CV-1046-GU1001 (6)

CC-1106-HL5015 RH-1201-RR0004 CC-1504-RR0013 CC-1412-HL5001 FC1016-HL5001 EW-1285-HL5001

'BA-1003-HF5005 CH-1203-HL5017 CS-1001-RR0012 (2)

'EW-1383-HL5006 CS-1001-HL5007 CV-1088-RR0019 CC-1474-GU0 CV-1047-RR1004 (7) CC-1317-HL5006 (3)

EW-1383-HL500 CC-1480-RR0011.(8) SI-1201-HL5015 (11)

.SI-1301-HL5010 (9) CC-1103-HL5003 SI-1201-HL5009 (10)

CC-1210-SS01 (12) 'CC-1101-HL5001 (13)'CC-1209-HL5004

- RH-1205-HL5002 (14)- CC-1210-HL5001 CC-13-3-HL5003 (15)

SIl05-RR0038 (16) CV-1046-RR1002 (1)7 of 14 fillet welds undersized. Class 7 ite Item still

'"in process".

-

(2) Two undersized skewed fillet welds and two undersized fillet weld Item still "in process".

(3) Fillet' weld from spring can to base plate undersize NCR-CS-321 (4) 'Two fillets un'dersize ~

NCR-CS-0320 Item still "in process".

(5) Seven fillet welds undersize NCR-CS-0319 (6) One' undersized fille Class Engineering accepted "as-is" during' audi (7) Two fillet welds undersize Class; NCR-CP-0314 (8) Three of four skewed fillet welds undersize NCR-CS-0320 (9) One skewed fillet welds undersize NCR-CS-0319 (10) Two skewed welds specified as groove welds were actually seal welds. NCR-CS-0084 (11) Four skewed fillet welds undersized, two gusset plates missin Item still "in process".

(12)~W8X31 section bent through the we NCR-CS-0319 '(13) Two undersized fil.let Item still "in process".

(14) Two welds located on the accute side of a skewed joint instead of'the obtuse side as specified on the drawing.- NCR-CS-0316 (15) One skewed fillet weld undersized on throat. Two fillet welds undersize NCR-CS-0320 .(16) One skewed fillet weld undersize NCR-CS-0087 IV-15

}

=

-TABLE IV-2 SUPPORTS WHICH WERE VISUALLY INSPECTED DW-1501-HF5005 DW-1501-HF5006 DW-1501-HF5004 SI-2205-HL5020 CC-2317-RR0012 CC-2115-RR0006-

' CC-2115-RR0005 CV-2088-HL-5006 CV-2086-HL5010-CC-2209-RH0009 CC-2209-RH008 CC-2109-RR0009 CC-2109-RR0008 CV-1214-HL5002

IV-16  ;

. _ . - . _ __ _ ,

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

TABLE IV-3 LIST OF PIPING'WHICH WAS VISUALLY INSPECTED

'

ITEM DESCRIPTIO PIPE' SIZE (IN.) MATERIAL

,

'

CC-211 ' Component Cooling '10 Carbon Steel CC-2114 Component Cooling '10 Carbon Steel CC-2117L Component Cooling 14 Carbon Steel CC-2317 Component Cooling 10- Carbon Steel CC-2115 Component Cooling 10 Carbon Steel

.BA-2001 Breathing Ai Stainless Steel CV-2086 ' Chemical / Volume Control 4- Stainless Steel CV-2088 Chemical / Volume Control 4 Stainless Steel CV-2006' Chemical / Volume Control 4 Stainless Steel ;

CV-2092 Chemical / Volume Control 4 Stainless Steel !

-CC-2109 Component. Cooling 12, 24 Carbon Steel-CC-2209 -Component Cooling 30 Carbon Steel CC-2410 _ Component Cooling 12 Carbon Steel CC-2110 Component Cooling 24 Carbon Steel CC-2109 Component Cooling 20 Carbon Steel EW-220 Essential Service Water 30 Aluminum Bronze CV-1111 Chemical / Volume Control 2 Stainless Steel

.CV-1112 Chemical / Volume Control 2 Stainless Steel CV-1209 Chemical / Volume Control 2 Stainless Steel

.CV-1106 Chemical / Volume Control 2 -Stainless Steel CV-1205 Chemical / Volume Control 2 Stainless Steel-

.CC-1515 Component Cooling 2 Carbon Steel CC-1479 Component Cooling 2 Carbon Steel CC-1401: Component Cooling 3 Carbon Steel CC-1402 Component Cooling 3 Carbon Steel:

CC-1403- -Component Cooling 3 Carbon Steel SA-1756 Station Air l' Carbon Steel FP-1506 Fire Protection 4 Carbon Stee '

CC-1106 Component Cooling 16- Carbon Steel FC-1016 _ Fuel Pool Cooling 10 Stainless Steel

~CC-1504 Component Cooling 6 Carbon Steel CS-1002 Containment Spray 8 Stainless Steel

.CC-1417 Component Cooling 14 Carbon Stee '

FW-1016 Feedwater 18 Carbon Steel FW-1018 Feedwater 18 Carbon Steel RH-1201 Residual Heat Removal 12 Stainless Steel CC-1474 Component Cooling 6 Carbon Steel CC-1318 ' Component Cooling 14 Carbon Steel

'

CS-1001 Containment Spray 8 Stainless Steel EW-1285 Essential Service Water 30 Aluminum Bronze EW-1383 Essential Service Water 30, 10 Aluminum Bronze CV-1088 Chemical / Volume Control 4 Stainless Steel CV-1047 Chemical / Volume Control 4 Stainless Stee CC-1480 Component Cooling 8 Carbon Steel CC-1103 Component Cooling 16 Carbon _ Steel

~CC-1201 Component Cooling 24 Carbon Steel SI-1201 ' Safety Injection 12, 16 Stainless Steel

.SI-1301 Safety Injection 12 Stainless Steel

.CC-1412 Component Cooling 4 Carbon Steel i

IV-17

-

__

l

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

TABLE IV-3 .(Continued)

LIST OF PIPING WHICH WAS VISUALLY INSPECTED ITEM- DESCRIPTION PIPE SIZE (IN.-) MATERIAL CC-1209' Component Cooling 20 Carbon Steel

' CC-1309 Component Cooling 20 Carbon Steel

CC-1203- Component. Cooling 20 Carbon Steel CC-1209. Component Cooling 20 Carbon Steel CC-1527 Component Cooling 12 Carbon Steel CH-1029; Chilled Water 12 Carbon Steel CH-1053- Chilled Water 12 Carbon Steel CC-1425 Component Cooling 4 Carbon Steel'

- RH-1102 Residual Heat Removal 12 Stainless Steel

.

I

. -

?

IV-18

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

TABLE IV-4 PORTIONS OF' PIPING SYSTEMS VISUALLY EXAMINED AND FOR WHICH DOCUMENTATION WAS REVIEWED ITEM DESCRIPTION PIPE SIZE (IN.) MATERIAL MS-1004 -Main Steam 30 Carbon Steel FW-1014- Feedwate Carbon Steel FW-1012 Feedwate Carbon Steel SI-1201 Safety Injection 16 Stainless Steel

i.

IV-19

-

TABLE IV-5 TANKS PRESSURE VESSELS AND HEAT EXCHANGERS WHICH WERE VISUALLY INSPECTED ITEM MANUFACTURER NOTES Accumulator. Tank SIATAT-02 Southwest Fabricating and Welding (1)

CCW Surge Tank 3R201NTS101A Brown-Minneapolis Tank (2)

CCW Heat Exchanger 3R201NHX101A Struthers-Wells, Inc (3)

RHR Exchanger 2R161NHX101B Jcseph Oat Corporation (4)

Dimineralizer' Tank 3R171NDM102A Westinghouse Pensacola Spray Additive Tank.TGXSIATSA-03 RECO Industries, In (5)

DFO. Storage Tank 3Q15MTF0337TK21 Brown-Minneapolis Tank (6)

Volume Control Tank'TGXCSATVC-01 RECO Industries, In (7)

Fuel Pool Cooling HXTXSFAHSF-02 Atlas' Industrial Manufacturing-(1) Bolting ring fillet welds intermittently undersized on one le NCR HM-03081 (2) Reinforcing fillet weld at various nozzles, manway neck to flange fillet weld and support fillet welds undersized.- NCR HM-0307 (3) Fillet weld from nozzle reinforcing pad to shell undersized. One reinforcing fillet weld at a 1" nozzle to shell weld undersized. NCR HNO307 (4) Reinforcing fillet at three nozzle to shell welds intermittently undersize NCR HN-0302 (5) -Arc strike on vessel shel NCR HM-0308 (6) Shell access hole re'inforcing fillet at nozzle to shell and fillet at flange face undersized. Manway to shell reinforcing fillet undersize Roof vent nozzle to roof reinforcing fillet weld undersize One fillet weld undersize NCR~HM-0309 (7) Manway nozzle fabricated as a nozzle with reinforcing pad instead of integrally reinforced butt welding fitting as required by drawin Stiffening ring to vessel shell fillet welds undersized. .NCR HM-0309 IV-20

TABLE IV-6 VENDOR RADIOGRAPHS-REVIEWED Castings Valv Spot Feet of Contractor Welds Pumps Welds Welds Film Notes G&W Energy 4 8-Products TRW Mission 2 8 (1)

Manufacturing Anchor Darling 56 775 Pacific Valve 1 4 Quaker Allo Teledyne~ Brown 8 8 Pall: Trinity 8 72 Sandusky.Fo6ndry 39 169 Master Craftsman- 16 16 Lanco 46 46 Joseph Oat 114 114 Richmond Engineering 206 206 (2)

Brown Minneapolis 508 508 (3)

Westinghouse 1041 1436 (4)

PDM 100 '200 Southwest Fabricating 14 (5)

Copes-Vulcan 4 98 Esco 1 88 Reco Industries 8 65 Pacific Pumps 8 67-Wollaston Alloys- 1 22 McJunkin Cor IV-21

. TABLE IV-6 --(Continued)

VENDOR RADIOGRAPHS REVIEWED Castings .

.

._ . Valve Spot Feet of Contractor' _ Welds Pumps' _Weld Welds Film Notes Combustion En ' 182 Fisher Controls 3 133 Sabine Steel- 43 43 (6)

NOTES:

(1) Reader sheet was not found in the. package. The sheets were later found and film was reviewed and no further problems were identifie (2) Yellow film was found in the film packages for the Volume Control tank and Lthe Pressure Relief Tank. The licensee issued SDR #-192 to cover this deficienc ~(3)' Microbiological Induced attack was found to have occurred during the storage

-

'

-

period of the tank However, '.he-licensee has rework all BMT supplied tank-and the final condition of the tanks is considered acceptabl _( 4) Linear-indications found in the backing ring welds in the demineralizer tank serial #37740. Yellow film was found in a.16 inch surge line, however the line was deleted by a design chang NCR #AN-03028 and AN-032 (5) Cylinder P4131, weld W-K-H-69 showed no evidence of retakes although the reader sheet indicates some were shot. Cylinder _4133, weld W-K showed a linear indication 3/4 of an inch long at interval no. 2. This appears on the films for intervals 1-2 and 2- .(6) Problem areas included questionable film,. disorganized reports, some pages were unreadable due to light copy, it was therefore unable to coordinate film-with data sheets. Also some repair _ film for rejects seemed to be unavailable. After some time HL&P determined that the light data sheets were apparently duplicates of other readable data' sheets. Also it was determined that the apparently missing film areas-were covered by film shot by Ebasco after.they had. repaired the questionable areas. The film was reviewed and

- no further problems were identifie IV-22

-

V. -CIVIL AND STRUCTURAL CONSTRUCTION Objective The objective of-the appraisal of civil and structural construction was to determine by evaluation and review of Quality Control (QC)

accepted work and documentation whether civil and structural construc-tion areas were completed in accordance with regulatory requirements, Safety Analysis Report commitments, and project specifications, drawings and procedure Discussion The specific areas of civil and structural construction evaluated included: reinforced concrete construction including mechanical splices, and concrete pour packages; structural steel installation including high strength bolting for structural steel friction and sliding connections; backfill and earthwork construction; the concrete expansion anchor bolts; and the containment post tensioned syste This evaluation included hardware and selected documentatio This portion of the NRC CAT inspection of concrete expansion anchors was limited to the review of the qualification test report. The inspection of installed concrete expansion anchors was performed by NRC CAT electrical and mechanical groups (see Sections II and III).

Parts of the above hardware inspection included verification of hardware to a sample of design change documents. The documents reviewed are listed in Section VII, Table 7 . Reinforced Concrete Construction a. . Inspection Scope Reinforced concrete construction ~ areas inspected by the NRC Construction Appraisal Team (CAT) included reinforcing steel configuration, activities for two concrete placements, in-process mechanical splicing, Quality Control (QC) documentation for -

mechanical splices and concrete placement, and general concrete surface qualit The reinforcing steel for three concrete placements were inspected for proper bar diameter, spacing and length. Embedded plates and anchor bolts which were part of the concrete placements were inspected for proper size and spacin Activities for two concrete placements were observed by the NRC CAT. Activities observed were batch plant mixing operations, concrete placement, tests for slump, air content and unit weight, length of time required. for concrete placement from truck mixers, and preparation of concrete cylinder test specimens. For one of V-1

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

,

k the two concrete placements, the general surface quality after the forswork had been removed was_ inspecte In process mechanical i splicing activities were observed by the NRC CAT. QC documentation

~

and appropriate field procedures were reviewed for. concrete placements and mechanical.' splices completed by Ebasco Constructor A review of the licensee's Phase A statusing of_QC documentation

_

for concrete placements and mechanical splices was performed. The purpose of the licensee's Phase A statusing was to determine the -l status of construction and QC documentation of work performed by '

Brown and. Root at the time when engineering and construction services were turned over to Bechtel Engineering and Ebasco ,

i Constructors. In addition, the qualification records for four cadwelders were reviewed. ~

$' Concrete placement. records reviewed included concrete pour pre placement checklist, in process concrete pour placement

'c checklist, concrete pour curing and post placement checklist, and concrete compressive strength test. report. The reviews checked the forms for' adequate completion by the QC inspectors, existence of senior QC inspectors' signature for evaluation of completed forms when necessary, and acceptable coverage of various

, inspection attribute ; 'Cadweld QC documentation reviewed by the NRC CAT included the 5 j cadwelder test record report, the tension test report of cadweld

rebar splices, the cadwelder qualification report, and the cadweld

(visual) inspection report. This review also verified whether or i not the forms had been adequately completed by the QC inspectors,

.' had been signed off by a senior QC inspector, and had acceptable- *

] coverage of various inspection attribute , By a general walkdown, the surface' quality of completed concrete work was observed by the NRC CA The requirements and acceptance criteria for reinforced concrete construction were obtained from the drawings listed in Table i V-1 and the following specifications and procedures:

i

• Bechtel Construction Specification 2A010CS1004, Rev. 2, "Spect-

. fication for Mechanical Splicing of Reinforcing Bars,"

January 18, 1985

• Bechtel Construction Specification 2A010CS1009, Rev. 4, "Speci ,

fication for Forming,.P13cing, Finishing, and Curing of Concrete,"

.

,

-

< March 28, 1985

• Ebasco CSP-4, Rev. 5, " Concrete Placement," June 28, 1985

• Ebasco QCP-10.1, Rev. 5, "Cadweld Inspection," September 20,

,

1985 i

i * Ebasco QCP-10.2, Rev. 5, "Preplacement Concrete Inspection,"

August 14, 1985 i

[ V-2

!

- - - - - . - . - . - - - . - , - . . - - - . - . - - - -

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

,

• Ebasco QCP-10.3, Rev. 5, " Concrete Placement Inspection,"

August 12,-1985 Inspection Findings

<

The inspection of installed reinforcing steel for the two concrete placements found no hardware deficiencie Activities observed for the two concrete placements as well as in process mechanical splicing of reinforcing steel were found to be adequat The licensee's Phase A statusing for concrete pour packages and grouting packages reviewed a list of documents for 100 percent .

of the activities. This list was. developed from the requirement in Brown and Root Procedure CCP-25. A concrete document checklist

~

, had been prepared by the licensee for Phase A statusing of concrete pour packages to-identify existing and missing (if any) QC documen-tation. The NRC CAT sampled one concrete pour package including six sets of associated QC documentation to verify if the contents in the concrete pour package matched those indicated on the concrete document checklist. No concerns were identifie The licensee's Phase A statusing for mechanical splice QC docu-mentation reviewed the documentation of cadwelds made by Brown and

>

Roo Two forms, a cadwelder qualification and testing report and a cadweld walkdcwn and documentation checklist, were prepared

<

by the. licensee for Phase A statusing to identify existing and

. any missing records related to mechanical splices. The NRC CAT reviewed the Phase A statusing work by sampling one cadwelder and one cadweld.' One concern was identified with the cadwelder

., qualification and testing report for cadwelder No. 43. The space

. box for the "two in ea. subsequent 100" column of the " horizontal-requalification" row had been marked "S" for satisfactor However, it should have been marked "U" for unsatisfactory. The ,

NRC CAT was informed that cadwelder No. 43 was the only Brown and

. Root cadwelder requalified. Based on the information that no other cadwelder was requalified and that the error was only with the tensile testing frequency implemented after cadwelder No. 43 was

'

e requalified, the NRC CAT feels the error to be an isolated on Nonconformance Report (NCR) No. GC03199 was issued to address the concern. Also, the dates listed in the " Dates Qualified To" spaces for the " vertical qualification" and " horizontal qualification" parts of the cadwelder qualification summary were found to be E reversed. The licensee subsequently documented this concer The NRC CAT found no concern with the cadweld sample checked against the contents of the cadweld walkdown and documentation checklis During a general walkdown, the NRC CAT identified a crack in the ,.

Unit 2 azimuth 304* tendon access wall at elevation (-)13 ft. 3 inches. This area was subsequently chipped out. It was then identified that the 3 inch seismic joint material had not been installed as required by drawing 3M01-9-C-4230R0 between the l Reactor Containment Building mat and the tendon access wal V-3

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

-

"Y

~Bechtel Engineering (BEC) issued NCR HCO3170.and state'd that-the

~

disposition-of. this' NCR would be to use as is. The stated basis of

- ;the disposition was that all settlements had taken place, the bearing surface area was small, and the -vertical seismic movements would be small at this locatio The NRC CAT's review of this issue found that BEC's disposition did not adequately address the seismic movement of the mat and the

'previously predicted unfavorable relative heaves of the two adjoining buildings once the dewatering system is discontinue Whether predicted unfavorable soil heave between the Reactor Containment Building and the Mechanical and Electrical Auxiliary Building could. create added unacceptable forces on the tendon access wall r.eeds to be addresse , Conclusion

-

In general, reinforced concrete construction appeared to be adequate. The review work performed for Phase A statusing on the Brown and Root concrete pour and mechanical splicing QC documenta-tion appear ~ed to be thorough. The documentation concerns with the mechanical splice QC records did not appear to affect the hardwar Under certain conditions the omission of the seismic joint between adjacent concrete structures could cause significant structural damag . Structural Steel Inspection

. Inspection Scope Installed and QC accepted structural steel members and connections were-inspected by the NRC CAT. Attributes ' inspected were member size, configuration, and bolted connections. For bolted connec-tions, both friction and sliding connections were tested by using a

,. calibrated torque wrench to detemine whether the bolts had proper L pretension. In addition, the bolts were inspected for proper

. material and nut engagement on the bol The 1, ample used in the structural steel verification for correct

? member size and configuration is described in Table V-2. A total of 93 structural steel members and 39. connections were inspecte The location, bolt size and material type, and number of ~ friction and sliding type connections which were checked for proper pre-tension are shown in Tables V-3 and.V-4 respectively. These bolts were sampled from structural steel connections although both samples are separate from those nentioned above as inspected for configuration. Test torque v0 ns were obtained by using a Skidmore Whilhelm tension testm to establish the proper torque-tension relationshi The requirements and acceptance criteria for structural steel installation are included in the drawings listed in Table V-5 and in the following specifications and procedures:

.

V-4

_ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

-_

. _ _

• Bechtsi Construction Specification 3A010SS0012, Rev. 3, F " Category I Structural Steel," December 4, 1984

~

• Bechtel Construction Specification 3A010SS0030, Rev. 5,

" Erection of Structural Steel and Miscellaneous Steel,"

July 26, 1985

• Ebasco CSP-10, Rev. 6, " Erection and Boltup of Structural-Steel," September 19,'1985

• Ebasco QCP-10.5, Rev. 5, " Inspection of Structural Steel Erection and Bolting," July 19, 1985 Inspection Findings Of the-93 structural steel members and 39 connections inspected for correct member size and configuration, only one hardware configuration deficiency was identified. This deficiency involved

~

.one column base connection being installed without nuts on one of its anchor bolts. Deficiency Notice 2-510-C was issued to repair the conditio A total of 648 7/8 inch diameter A325 high strength bolts were checked _ for proper installed torque for structural steel friction type _ connections.-- The installed torque values of twenty-three (approximately 4 percent) of the 648 7/8 inch diameter A325 bolts were significantly below the inspection torque of 450 ft-lbs. . Four of the 23 were found to be installed loose. NCRs CC03132 and CC03134 were written to repair the improperly installed bolts. All twenty-three bolts were to be properly tightened. The remaining 625 bolts were determined to be acceptabl Thirty-two 7/8 inch diameter A490 high strength bolts were checked for proper installed torque. The sampled bolts were installed above the inspection torque value of 550 ft-lbs and determined to be acceptabl '

For the sliding type structural steel connections, a total o >7/8 inch diameter A325 high strength bolts were inspected for proper installation torque. Forty-three of the 68 A325 bolts were installed at torque values greater than the inspection torque value of 150 ft-lbs. Twenty-five of the 43 'over-tightened bolts were installed at torque values greater than 500 ft-lbs. NCR-CC03190 was written to document and disposition the deficienc All of the sampled ' sliding connections had inspection markirgs indicating that they had been inspected. The inspection criteria for sliding connections states that the bolts be installed snug tight. : Snug tight is defined as the full force of a man on a

~

spud wrench. Based.on such a vague inspection criteria, neither the NRC. CAT'nor the licensee was able to. determine how these _

connections could have been inspected. The NRC CAT finding indicates that more specific inspection criteria is necessary to V-5

- _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -- A

..

inspect the sliding connections adequately. The licensee has committed to write adequate inspection criteria in the current specifications and to reinspect all sliding. connection It was found that project specifications allow welding across the flanges on fully loaded structural steel members. The NRC CAT asked if an engineering evaluation had been performed (similar to that indicated in AWS D.1.1, Section 7.5.1) to determine, due to extent of cross-section heating, whether or not a member is permit-ted to carry a live-load stress while welding on it. No specific analytical evaluation of whether the welding across the flange could weaken the affected structural steel member was provided to the NRC CAT. BEC ju'stified the specifications based on general engineering judgement and historical knowledge. This engineering response, without the supporting evaluation, is considered inadequate.

c. Conclusion In general,-utructural steel members and connections for size and configuration verification were .found to be installed properl The high strength A325 and A490 bolts for friction type structural steel connections were generally determined to be installed adequately. The lack of adequate inspection cri_teria for sliding connections resulted in the acceptance of a deficient installatio All sliding connections should meet the new inspection criteria when established by the license An evaluation should be conducted. showing that the practice of cross flange welding has not and will not overstress loaded members.

3. Backfill and Earthwork Construction a. Inspection Scope The daily reports and backfill compaction records'for the Essential Cooling Water (ECW) pipe trench backfill were reviewed. The backfill compaction work activities and in situ sand cone tests in area II40, northeast of the Unit 1 Diesel Generator Building, were witnessed by the NRC CA The requirements and acceptance criteria are contained in the following specifications:

• Bechtel Construction Specification SY069YS0043, Rev. 12,

" Structural Excavation and Backfill".

• Bechtel Construction Specification 2Y060YS0044, Rev. 5, " Field and Laboratory Testing of Earthwork Construction".

V-6

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

d t

Inspection Findings

{ The daily. reports and backfill compaction records appeared _to 3 be complete'and in accordance with the project specification J The backfill work activities observed by the NRC CAT northeast

'

of the Unit'l Diesel Generator Building at elevation +26.0 was L properly placed and compacted.

F -The NRC CAT inspectors-identified a potential problem which may

, not.have been addressed by the licensee. The ECW pipe trench is i

. supported on a highly plastic A 2 clay laye This clay layer will shrink when dried and expand as the clay particles absorb

'

_

-

water. Since 1975 the. site dewatering system has been in operation and the ground water level has fallen below the A2 clay laye +

,

During this dewatering period the clay layer could have lost

'

i significant moisture. The site dewatering system is scheduled to be discontinued prior to plant operation. When this occurs, th s

<

ground water level will be re-established to about-its pre-1975 level. If,the moisture. content of the clay layer during the 1 dewatering period has been reduced significantly and then the

, dewatering system is discontinued, the clay layer when exposed to

, the returned ground water is expected to expand. The issue _of whether this clay layer will expand and whether.the expansion will

-

occur uniformily_ appears not to have been properly considered to date. This along with other data on the thickness of the clay

,

, layer, the placticity index of the clay, the confining pressure and

, 'the quantity of water absorbed by'the clay particles, and the in situ moisture content of several points at various levels in the

'

' clay layer during the dewatering period will also need to be

,

considered. The concern is whether the expansion of the underlying ,

- and adjacent clay could cause differential-displacements of the ECW  ;

pipes. Also, whether.this potential.for ground movement could

'

cause the ECW pipes to become overstressed. The licensee was not able to provide information on such.a review during the NRC inspectio Conclusions

The structural backfill compaction records and the structural backfill reviewed by the NRC CAT inspectors were generally _found

'

-

l to be acceptabl The licensee should investigate the potential of the expansive

. clays to swell upon return of ground water to normal levels and the potential affect of this swelling on the ECW piping.

Concrete Expansion Anchor Bolt Qualification Test Report

, Inspection Scope "

i-

'

The qualification test report for the wedge type concrete expansion anchors was reviewed for technical adequacy, conformance to

.

project specifications and demonstration of satisfactory anchor

performance.

L i

-

V-7

,

• &

'

,-w ey,=. < , ,,w,,,,- - .

,.,,e y,,,,_,w,y .-.r_.my, .-, ,--,.g ..

.,,my, ,

<

The following qualification test report was reviewed:

• Wiss, Janey, Elster and Associates, Rev. 2, " Tension, Shear and Relaxation Testing of Expansion Anchors at the South Texas Project, Bay: City Texas", May 29, 1981 The requirements and acceptance criteria are contained in the following documents:

• Bechtel Construction Specification 5A010SS1000, Rev. 7,

" Installation of Expansion Anchors, Rock Bolts, Grouted Anchor Bolts, and Core Drilling" Ebasco CSP-41, Rev. 6, " Installation of Expansion Type Anchors"

• Ebasco QCP 10.19, Rev. 7, " Inspection of Anchoring Devices Installed Within Concrete Structures" Inspection Findings The allowable loads used in the design of concrete expansion bolts (CEAs) was based on the average results of the tests divided by a factor of safety of 4. For the 1/4 inch diameter CEAs with 1-1/8 inch embedment the average maximum load for 4070 psi concrete is 890 lbs. The allowable tensile load is 250 lbs. This allowable load does not meet the factor of safety of 4 criteria specified in Inspection and Enforcement Bulletin 79-0 For the 1-1/4 inch diameter CEAs, the anchor slip at the design tension loads is greater than 1/16 inch for 8-1/2 inch embedment and 3/16 inch for 10-1/2 inch embedment. The shear tests show similar results. The licensee has stated that the 3/16 inch movement at the design loads was unacceptable and that the allowable loads will be reduced. The licensee stated that for the 1/16 inch slip, the current design load is acceptabl The-NRC CAT finds the licensee's response for the 1/16 inch slip at the current design loads to be inadequate. The results in the test program for anchor bolts are for one time loading. However, reliance solely on the referenced test program without considering, in actuality, that within the plant the maximum design load may be applied more than one time, is considered inadequate. Since most of the slip is likely to be permanent, these deflections will tend to accumulate with each load application. Also, the 1/16 inch deflection in shear and tension may be considered unacceptable in many piping analysi c. Conclusion The licensee should reevaluate the~ allowable design loads used for concrete expansion anchors. This reevaluation should take into account the magnitude of anchor slip at the design load and consider the shear, tension, deflections, and the piping systems that are supporte V-8

_-

5. Containment Post-Tensioned System Inspection Scope The installation records of 8 Unit 1 prestressed tendons were reviewed. The NRC CAT also observed.various stages of tendon installation work activities which include the pulling, button-heading, stressing, and greasing of the tendon The requirements and acceptance criteria were included in the following specification and procedure * Bechtel Construction Specification 2C239CS0003, Rev. 4,

" Containment Post Tensioning System," July 15, 1985

• FIM-STP-01, Rev. O, " Procedure for Cleaning and Checking-Post Tensioning Embedded Items," August 8,1984

• FIM-STP-H-1, Rev. 1A, " Installation, Buttonheading, Stressing and Greasing of Horizontal Tendson," August 29, 1985

• FIM-STP-V-1, Rev. 3A, " Installation, Buttonheading, Stressing and Greasing of Vertical Tendons," August 29, 1985

• FIM-VCP-01, Rev. 2, " Tendon Void Clearing Procedure," May 22, 1985 FQCP-STP-03, Rev. 3, " Quality. Control Procedures - Vertical and Horizontal Tendons," July 9, 1985

• STP-FTP-1, Rev. 4, " Friction Test Procedures," August 13, 1985 b. Inspection Findings

. ,

The review of installation records and the observation of various stages of tendon installation work activities indicated that the post-tensioned system was being installed in accordance with the specifications and procedures.

c. Conclusions The installation of the containment post tensioned system was found to be in accordance with applicable instructions and specification V-9

_

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

b

_

TABLE V-1 DRAWINGS USED FOR REINFOR'C D CONCRETE CONSTRUCTION INSPECTION

[DrawingN Re Title t

193AB- -B (Shop Drawing)

t 193BC (Shop Drawing)

] 193C A (Shop Drawing)

-2C22-9-S-1012 1 Steel Reactor Containment Building Dome Liner - Plans -

-and Sections and Details

,

2C22-9-C-1033 5 -Concrete-Reactor Containment Building Dome Reinforce- '

,

'

ment.- Plan 2C22-9-C-1034 2 Concrete Reactor Containment Building Dome Shell"-

i Sections and Details

2C22-9-C-1036 0 Concrete Reactor Containment Building Dome Tendon - i Anchorage Location j J2C23-9-C-1021 1 Concrete Reactor Containment Building Post Tensioning System

'

3A01-0-C-0001 20 -Concrete Structural St'andards General Notes 3A01-0-C-0011 14 Concrete Structural Standards General Notes-3M01-2-C-4026 Concrete Mechanical & Electrical Auxiliary Building

, Floor Plan 9 E1. 41'..-0" i

3M01-9-C-4241 2 Concrete Mechanical & Electrical Auxiliary-Building =

Std.: Wall Reinf._ Details E1. 29'-0" to Roof (U.N.0.)

p'

3M01-9-C-4242 1 Concrete Mechanical and Electrical Auxiliary Building Miscellaneous Details .i j 3M01-9-C-4309 3 ' Concrete Mechanical and Electrical Auxiliary Building i d

Miscellaneous Sections-and Details

-

3M05-9-C-4009 5 Concrete Mechanical and Electrical Auxiliary Building Foundation Plan 9 El. 10'-0"

i J

Y'.

.

,

J V-10

.-. - -. -

. . - . . . - _ _ - . . .. a .-. - . - - . . . . . . - . - ...-.;-. . . - - - -.

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

-

.

j

. TABLE V-2 INSTALLED STRUCTURAL-STEEL INSPECTION SAMPLE i Unit ~ Number Approximate Truss

. and Building- Elevation Comments Beans Braces Columns Connection @ @ers

.

Unit 1- 68 ft 14 -

2 3 -

'

Reactor .

'

- Containment 52 ft 5 .1 - - -

,

37 ft 2 - --

.- -

-2 ft 2 -

1 3 -

Unit 11 118 ft 5 - -

8 11 Sample Taken Fuel Handling-. From Roof Trusses and Framing -'

Unit-1 69 ft ~5- - -

5 3

, Mechanical'& and Electrical 6 inches t . Auxiliary

.

74 ft 3 -

3 3 -

_ _ _ _ _

Total 36 1 6 22 14

'

,

t L

e

$-

t

,

k r

V-11

,

,. , ..

-

~,__,.._.,,-_,-w,,,,,,,_ , _ . . _ _ . . _ , . , - . , ,,_,,_.r, _._,,_m.,. _ . . ~ . , . . , . . , . , . . , . . _ , . _ , , ..,,.%

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

-TABLE V-2 (Continued)

,

INSTALLED STRUCTURAL STEEL INSPECTION SAMPLE

~

Unit Number- Approximate and Building Elevation Beams Columns Connections Comments Unit 2 .

10 ft - -

1 Deficiency Notice

. Mechanical & 2-510-C was issued Electrical to repair the Auxiliary anchor bolts of column base connection ft 5 2 6 35 ft 3 2 3

.

58 ft 8 3 5 Unit 2 52 ft 5 -

Reactor Containment 68 ft 8 -

_ _ _

-

Total 29 7 17

.

.t i

I

v

'

V-12

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

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

. .

,

I TABLE V-3 HIGH STRENGTH BOLTING FOR FRICTION CONNECTION INSPECTION SAMPLE Number of Number of Number of Bolts Checked Bolts Installed Unit Number- Bolt Size Friction for Proper Below Inspection

!

-and Building and Type- Connections * Installation-Torque

-

Torque Comments Unit 1 7/8 inch .15 144 5 See note 1 Reactor dia. A325 Containment Unit 1 7/8 8- 77 8 Mechanical & dia. A325 Electrical Auxiliary Unit 2 7/8 inch 12 172 0 Reactor dia. A325 Containment Unit 2 7/8 inch 20 255 13 Mechanical & dia. A325'

. Electrical Auxil'iary Unit 2 7/8 inch 1 32 0 See note 2 Reactor dia. A490 Containment Note 1: The inspection torque value for 7/8 inch dia. A325 bolts was 450 ft. lb Note 2: The inspection torque value for 7/8 inch dia. A490 bolts was 550 ft. lb *The connections sampled are separate from the structural steel connections inspected in Table V- V-13

-

TABLE V-4 HIGH STRENGTH BOLTING FOR SLIDING CONNECTION INSPECTION SAMPLE Number of Bolts Number of Bolts Installed Above

_ Number of Checked for Inspection Torque Unit Number Sliding Proper Installation and the Installed and Building Connections * Torque Torque Range Comments Unit 1 1 10 67 10 installed between All bolts were R; actor 160 and 200 ft-lbs 7/8 inch di A325. Approxi-5 installed between 'mately 63% were 200 and 250 ft-lbs found to be installed 28 installed above overtorque ft-lbs

"The connections sampled are separate from the connections inspected in Table Table V-2 and V- V-14

, :. :

TABLE V-5 DRAWINGS USED FOR STRUCTURAL STEEL INSTALLATION INSPECTION American Bridge Detail Drawings Order N Sheet N Revision N K-7023 E12 8 610AD .A-

~6100 -

'K-7024 E2 C E5 F E18 G E20 E E22- G E301- E E302 G 123 B 176 C 506 A 526 -

,

K-7025 E4 D E12 H E702 A 718 -

K-7029 E17 C E22 C 405 -

413 -

,

508 B 516 C K-7030 'El -

E2 -

E6 B E7 A E9 0 102 A 106 A V-15

TABLE V-5 (Continued)

DRAWINGS USED FOR STRUCTURAL STEEL INSTALLATION INSPECTION Bechtel Design Drawings Drawing N Re Title 1C01-9-S-1532 4 Reactor Containment Building Steam Generator, R.C. Pump Vertical and Pressurizer Lateral Support IC01-9-S-150 5 Reactor Containment Building Internal-Steel Framing Plan @ E1. 68-0" 3A01-05-0001 12 Steel Structures Standards General Notes 3C01-9-S-1502 8 Reactor Containment Building Internal - Steel Framing i Plan 9 El. (-)2'-0" 3C01-9-5-1505 Reactor Containment Building Internal - Steel Framing Plan @ El. 37'-3" 3C01-9-S-1508 5 Reactor Containment Building Internal - Steel Framing Plan 9 El. 52'-0'

3C01-9-S-1509 4 Reactor Containment Building Internal - Steel Framing Plan @ El. 68'-0" 3C01-9-S-1510 5 Reactor Containment Building Internal - Steel Framing Plan 9 El. 68'-0" 3C01-9-S-1511 1 Reactor Containment Building Coluc.n Schedule and Details 3C01-9-S-1528 8 Reactor Containment Building Internal Sections and Details 3C01-9-S-1539 2 Reactor Containment Building Internal - Miscellaneous Plan Sections and Details 3C01-9-S-1619 6 Reactor Containment Building Internal - Steel Alterations

@ El. (-)2'-0" 3C01-9-S-1621 5 Reactor Containment Building Internal - Steel Alterations 0 E1. 37'-3" 3C01-9-S-1622 3 Reactor Containment Building Internal - Steel Alterations O El. 52'-0" 3C01-9-S-1623 3 Reactor Containment Building Internal - Steel Alterations 9 E1. 68'-0" 3C01-9-S-1624 6 Reactor Containment Building Internal - Steel Alterations Details and Tables 3C01-9-S-1625 2 Reactor Containment Building Internal - Steel Alterations Details and Tables 3C01-9-S-1629 6 Reactor Containment Interal - Steel Alterations Details and Tables 3F01-9-S-3003 3 Fuel Handling Building Roof Framing Plan (Plan - Roof Truss 9 Top Chord and Roof Truss MK-TI)

3M01-9-S-4043 3 Mechanical and Electrical Auxiliary Building Framing in HVAC Areas El. 69'-6" U.N.

3M01-9-S-4060 4 Mechanical and Electrical Auxiliary Building Framing Plan @ Els. 21'-0" and 23'-0" V-16

,

TABLE V-5 (Continued)

DRAWINGS USED FOR STRUCTURAL STEEL INSTALLATION INSPECTION Bechtel Design Drawings Drawing N Re Title

'3M01-9-S-4065 4 Mechanical ~and Electrical Auxiliary Building Framing Plan 9 El. 35'-0" 3M01-9-S-4071 1 Mechanical and Electrical Auxiliary Building Framing Plan 9 El. 60'-0" 3M01-9-S-4082 4 Mechanical and Electrical Auxiliary Building Framing Plan 9 El. 72'-0", 74'-0" and 76'-0" 3M01-9-S-4090 4 Mechanical and Electrical Auxiliary Building Coluns Schedule and Standard Details

-

i W

V-17

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

VI. MATERIAL TRACEABILITY AND CONTROL Objective This part of the inspection effort was to verify that the identifi-cation and marking of materials and equipment used in the fabrication and construction processes have been maintained, and that the docu-mentation required to support traceability, to both the. design drawings / specifications and to the material sources, was retrievable and met regulatory requirements, PSAR commitments, and applicable codes and standard B. Discussion A total of 219 items were selected at random and identified as samples for the inspection. The items inspected were located in the storage yards, laydown areas, storage warehouses, outlying buildings, and various elevations and rooms in the reactor containment, auxiliary building, diesel building, and fuel handling building for both Unit 1 and Unit 2. Some items inspected were in storage and others were being installed. Some had been installed and were in a storage mode, and others had been installed and turned over to the operations grou Tables VI-1 through VI-8 indicate the areas where material / equipment samples were selected, and adequacy of the identification, trace-ability and documentation. The applicable reference documents reviewed and used during the inspection included the following:

Site Final Safety Analysis Repor * Specification 4A010GS1009, Safety Related Non-ASME Bolting Materials, Rev. * Specification 5A010GS1007, Civil / Structural Construction Materials, Rev. * Specification 3E189ES1000, Conduct and Tray Supports, Rev. * Procedure SSP-13, Material Control, Rev. * Procedure ASP-5, Material Control, Rev. * Procedure WPP/QCI-12.4, Material Identi*ication and Marking Requirements, Rev. 1 * Procedure QCP-9.4, Verification of Weld Filler Material Control, Rev. * Procedure WPP/QCI-18.0, EE580 Cable and Raceway Tracking Procedure, Rev. 1 * Procedure QCP-10.22, Receipt Inspection, Rev. 1 * Engineer and Constructor ASME Procedur VI-1

' * American Society for Testing Materials standard Equipment and components were inspected in order to verify that required identification codes were maintained on items such as civil construction materials, electrical cable and equipment, welding supplies, vendor supplied equipment assemblies, structural and mechanical item . Material Traceability Inspection Scope Two hundred nineteen samples were examined to determine if the identification and markings were traceable to the applicable specification, drawing, purchase. order, code data package, mill test report or a combination thereo The licensee's records management group. retrieved the requested documentation which was analyzed and compared to site requirements and field notes by the NRC CAT inspecto Inspection Findings During the inspection it was determined that a program for

. identification of materials and retrievability and adequacy of documentation was generally in place and functionin (1) The following were found to be satisfactory:

(a) The records management group uses a computer assisted program for retrieval of most documents that are considered complete. In process records are processed manually or by using sub programs (i.e., electrical EE580 program for. routing, terminations, cable type, etc.)

(b) Eighteen samples of different types of welding consumables as noted'in Table VI-1 were examined for markings, retrievability of documentation and adequacy of the documentatio (c) Fourteen samples of different types and sizes of electrical cables were inspected for identification, documentation and qualification requirements. These results were satisfactory as shown in Table VI- (d) Civil / Construction materials were inspected for compliance to the specification requirements. Thirty-one items were sampled and were found to meet the specification requirements as shown in Table VI- (e) Anchor bolts and embedded items were not a part of the traceability program due to the fact that a major program in this area was previously undertaken by the licensee and is awaiting review by the NRC. The NRC CAT inspector reviewed the structural bolting for an VI-2

=

{

Accumulator and Residual Heat Removal Heat Exchanger and noted that both were included in the licensee's repor (f) Table VI-4 summarizes materials and equipment that was inspected and is used in the Heating, Ventilating and Air Conditioning (HVAC) discipline including fans, motors and dampers. Tracability was.found to be satisfactor (2) Significant' weaknesses in the program were found in the following areas:

(a) The action taken for the disposition of FCR BE-00088 on the clarification of bolting material requirements for cable tray.and conduit supports was not effective in that it allowed the option of not .aposing the manufac-tures marking requirements of the specified national bolting standard without appropriate consideration of the measures needed to maintain the traceability and control of unmarked fasteners throughout the plan (b) Verification of markings / traceability of bolting materials used in the fabrication of large vendor supplied skid mounted equipment and used by the construction crafts in the fabrication and installation of electrical equipmen (3) The following' observations were made by the NRC CAT inspector and found to be unsatisfactory:

(a) Code data packages for the' Unit 1 Radwaste Holdup' Tank 7R32IXTS101A and Reactor Internals Disconnecting Device Pressure Housing, Board #18288 could not be_ located. As a result of the NRC CAT finding, the licensee issued Nonconformance Report BN-03015 to document the deficiency of Board #18288 and provide for appropriate corrective action. No written corrective action was noted during the NRC CAT inspection concerning the'

Radwaste Holdup Tan The code data package for an ASME 8-inch check valve was incomplete and a corrected copy of the certificate of welding was generated. As a result of the NRC' CAT finding, the licensee issued a Document Deficiency Notice QC-RN-15 The material type'as indicated on a code data report for an ASME 8 inch Safety Injection Check Valve Bonnet (valve #V1423) was different than that indicated on the mill test report. As a result of the NRC CAT finding, the licensee initiated NCR BN-03013 to document this discrepancy for corrective actio These and other ASME code data packages inspected are indicated in Table VI- VI-3

(b) Some documents that were requested to confirm bolting traceability of certain selected equipment samples summarized in Table VI-6 were not located and furnished for review by the NRC CAT inspector prior to the end of the inspection. Licensee representatives stated that actions would be. continued to locate applicable documentation and review bolting traceabilit (c) It was found by the NRC CAT inspectors that the specific requirement of the national standard ASTM A307 Grade B for marking of fasteners has been deleted by engineering from a specification for electrical raceway supports,

~

L without requiring adequate on-site material control during their installation (Reference FCR BE-00088 and Specification 3E189ES1000 for conduit and tray supports).

The deletion of marking / identification requirements for electrical equipment bolting has resulted in the uncontrolled distribution of bulk quantities of these items throughout the plant. This condition may have resulted in the indiscriminate use of the unmarked fasteners in other types of equipment installations because the bolting is readily available and presumed to be adequat Based on the above observations, the NRC inspector could not ascertain the appropriate use and traceability of the unmarked fasteners for the various electrical installations of the NRC CAT sample, and thus the quality of the fasteners is considered indeterminat (d) The bolting in 10 of 11 samples of electrical equipment was not found to be traceable when inspected for conformance to specifications or seismic report ~

Bolting used in fabrication and/or installation of the ten samples were not marked or had mixed marking The results are tabulated in Table VI- (e) Two sections of 2 inch schedule 160 stainless piping in storage were found to be mismarked. As a result of the NRC CAT finding,.QCI report G1649 was issued by the licensee to scrap the piece (f) Mechanical material and equipment was inspected to the specification requirements. Regarding bolting, several items were found to be of the correct type, identified and traceable. However, traceability deficiencies were found in 14 of 20 samples of bolting for large mechani-cal installations listed in Table VI-8. The following are five examples of such deficiencies:

VI-4

• Mounting bolts for the Essential-Coo. ling Water Wash Screen (3R281NPA102A) Motor were unmarke These are-required to be ASTM A193-8 As a result of the NRC CAT finding, the utility has issued NCR AM-03072 documenting the discrepancy for corrective actio * Motor mounting bolts for the Auxiliary Feedwater Motor

1. 13 were identified as~ ASTM A193-B7 and were required'

to be ASTM A307. The licensee, during the NRC CAT inspection, did not issue documentation to record this-discrepancy for corrective actio * Bolti~ng for the Containment Spray, High Head Safety Injection and Low Head Safety Injection Pumps, motors and transition pieces Nos lA, 2A, 3A, IB, 2B, 3B and IC, 2C, 3C were observed to be either unmarked, A307, A325 or A44 The correct bolting for these units is

~ ASTM A193-B7. As a result'of the NRC CAT finding, the licensee issued NCR'CM-03078 to document this discrepancy for corrective actio * Auxiliary Feedwater Turbine (3S141MTU01) driver bolting to the base was not identified or marke This material is required to be SA193-B7. As a result of the NRC CAT finding, NCR BM-03076 was issued to '

document this item for' corrective actio * Bolting on the Essential Cooling Water Strainer Flange

.(3R281NSP101A) by drawing was required to be cadmium plated. The specification allowed for cadmium or zinc plating, and the sample appeared to be zinc plate As a result of the NRC CAT finding, the licensee issued Field Change Request BP-00891 to change the drawings to include zinc ~ platin c. Conclusions In general, the material traceability and control program was considered to be satisfactory. However, lack of traceability was found for fastener materials for certain large sendor supplied

mechanical / electrical equipment assemblies mounted on skids and for certain electrical equipment and cable tray / conduit support Also, documentation to permit verification of traceability of fasteners for certain equipment was not located by the licensee

,' during the inspectio VI-5 i

L TABLE VI-1-WELDING CONSUMABLES

.. ITEM LOCATION COMPLIANCE 3/32 E7018 Test Shop Satisfactory

.093 E6010 Test Shop Satisfactory

'3/32 E7018 Test Shop Satisfactory 1/8 E6010 RCB II Satisfactory 1/8 308L-16 RCB II Satisfactory 3/32 308-16 RCB II Satisfactory 1/8 316-16 RCB I Satisfactory

.045 ERNICR-3 RCB I Satisfactory 1/8 E12018-M RCB I Satisfactory 5/32-308-16 RECO Satisfactory 5/32 308-16 RECO Satisfactory 3/16 309-16 RECO ' Satisfactory 3/32 E7018 DG Caddy Satisfactory 3/32 E7018 MEAB Caddy Satisfactory 5/32 E7018 MEAB I Caddy Satisfactory 5/32 E7018 MEAB I Room Satisfactory

.035 wire MEAB I Room Satisfactory 1/8 308-16 MEAB I Room Satisfactory VI-6

._ - .. _ _ _ _ .

'

TABLE VI-2 ELECTRICAL CABLE ITEM LOCATION COMPLIANCE 3/c #12

'

Reel yard Satisfactory 7/c #12 . Reel yard Satisfactory 3/c #12 ECW Structure Satisfactory

'2/c #16 Unit I laydown Satisfactory

-

1/c 500MCM Unit I laydown

~

Satisfactory 3/c #8 Unit I laydown Satisfactory 5/c #12 Unit I RCB El 68 Satisfactory 9/c #12 Unit I RCB El 50 Satisfactory 3/c #8 Unit I RCB El 24 Satisfactory 3/c #10 Unit I FHB El 73' Satisfactory i 2/c #12 Unit I MEAB El 65 Satisfactory 3/c #12 Unit I MEAB Satisfactory 5/c #12 Unit I MEAB El 35 Satisfactory-7/c #12 Unit I MEAB El 10 Satisfactory i

1

,

VI-7

- _ _ _ , . . . . . . _ . . . _ _ _ - _ . . _ . - . _ _ . . _ , _ - _ . _ _ TABLE VI-3 CIVIL / CONSTRUCTION MATERIALS Item Identifier Location Compliance

1. 9 Rebar T5-6275 Laydown Satisfactory

1. 10 Rebar S-16741 Laydown Satisfactory

1. 11 Rebar S-25074 Laydown Satisfactory Cadweld Powder N-7178 Storage warehouse Satisfactory Cadweld Powder D-24409 Storage warehouse Satisfactory Cadweld Sleeve S-2068 Storage warehouse Satisfactory Cadweld Sleeve S-1901 Storage warehouse Satisfactory W.R. Admixture B-12120-09W Batch plant Satisfactory A.R. Admixture B-11293-09V Batch plant Satisfactory Cement Grind #13 Batch plant Satisfactory Paint 111488 Paint warehouse Satisfactory Paint Cure 108220B Paint warehouse Satisfactory Paint Mix 112389 Paint warehouse Satisfactory Paint Powder 112260 Paint warehouse Satisfactory Cadweld Sleeve S-1798 Unit II RCB springline Satisfactory Cadweld Sleeve S-2082 Unit II RCB springline Satisfactory Structural Seam J72499 Unit II El 72 RCB Satisfactory Wall Embed 70479 Unit II El 45 RCB Satisfactory Structural Nuts 2H Unit II stairwell RCB Satisfactory Steel Column K7029 . Unit II RCB Satisfactory Floor Embed 2907 Unit'II El 35 control Room Satisfactory Threaded Rod NA Unit II MEAB El 10 Satisfactory Nuts DH Unit II MEAB El 10 Satisfactory Stainless Plate -13721 Condensate Tank Unit I Satisfactory C.S. Plate 401C7601 Condensate Tank Unit I Satisfactory 3" Shim 680015 Unit I FHB roof Satisfactory Wall Embed 52028 Unit I RCB El 60 Satisfactory Liner Plate 2425 Unit 1 RCB El 57 Satisfactory Anchor Bolts NA Unit I RCB El 2 Satisfactory Anchor Bolts NA Unit I RCB El 32 Satisfactory Floor Plate 3E1846 Unit 1 RCB Refuel Pool Satisfactory i

a VI-8

__ - -

F 1 TABLE VI-4 HEATING, VENTILATING AND AIR CONDITIONING Item Identifier Location Compliance Joy Fan 3V112VFN003 Warehouse C Satisfactory Bolts TB- Unit II MEAB El 60 Satisfactory Bolts ST Unit II MEAB El 60 Satisfactory Hange S056-RSI-28075 Unit II MEAB El 35 Satisfactory Damper 8V141VDA-043 Unit I RCB El 5 Satisfactory Ventilation Fan 8V141VFN-023 Unit I RCB El 6 . Satisfactory Cooling Coil 8V141VHX-004 Unit I RCB El 6 Satisfactory Fire Damper 1-3-0073-VD-101 Unit I.FHB El 47 Satisfactory VI-9

._

-

_ l 3 ,

. ,

[ TABLE VI-5'

ASME CODE DATA PACKAGES REVIEWED Item Location' Compliance 8". Check Valve: Warehouse D -Unsatisfactory-16" Gate' Valve  : Warehouse D Satirfactory

-

Instrument- Valve - -Unit II RCB Satisfactory Component Support - Unit II RCB Satisfactory-12" Pipe and Flange Unit II FHB- Satisfactory Spent Fuel Pool Heat Exchanger Unit II FHB- Satisfactory 10" Gate Valv Unit II FHB Satisfactory Ball Valve Unit II MEAB El 10" Satisfactory 6" Bronze Pipe ECW Building Satisfactory 24" Bronze Pipe

-

ECW Building Satisfactory-2" Pipe and Elbow -

Unit I FHB Satisfactory

8" Containment Spray Ring Pipe Unit I FHB Satisfactory

2" Globe Valve Unit I FHB Satisfactory Reactor' Internal Disconnect Device Housing Unit I RCB Not Retrievable

'30" Main Steam Pipe Unit I RC8 El 65 Satisfactory

~30" Main. Steam Pipe Unit I RCB El 35 Satisfactory Pipe'Pentration Unit I RCB Satisfactory

-

RHR Heat Exchanger Unit I RC8 Rm 306 . Satisfactory _

Flexible Instrument Line- Unit I RC8 El'35' Satisfactory-24". Gate. Valve ~ Unit I RCB El 24 Satisfactory 31" Crossunder Pipe- Unit I RCB El 2 Satisfactory 8" Safety Injection Check Valve Unit I RC8 El 6 Unsatisfactory Pressure Sensor Unit I RCB E1 32 Satisfactory 2": Solenoid Valve . ' Unit I DG8 El 32' ~ Satisfactory Spent Fuel Pool Heat Exchanger Unit I FH6 El 4 Satisfactory Spent Fuel Cooling' Pump Unit 1 FHB El 35 Satisfactory 14" Fabricated Pipe Unit I FH8 El 17 Satisfactory 3" Plug Valve . Unit I MEAB El 74 Satisfactory Component Cooling Water Surge Tank Unit I MEA 8 El 65 Satisfactory Recycle Evaporator Condensate Tank Unit I MEA 8 El 56 Satisfactory Waste Evaporator Condensate Tank Unit I HEA8 El 56 Satisfactory FTD Filter Unit I MEAB El 65 Satisfactory 2" Valvc Unit I MEAB El 65 Satisfactory-Radwaste Holdup Tank Unit I MEAB El 57- Not Retrievable Chemical & Volume Control Tank Unit.I MEA 8 El 46 Satisfactory Component Cooling Heat Exchanger Unit I MEA 8 El 29 Satisfactory Seal Water Heat Exchanger Unit I MCAB El 10 Satisfactory VI-10

t -

TABLE VI-6 TRACEABILITY DOCUMENTATION FOR BOLTING NOT FURNISHED Item Location Compliance Chilled Water Pumps Unit II MEAB El 10 Not Retrieved Centrifugal Charging Pump Unit II MEAB El 10 Not Retrieved Fire Pumps Fire Pump house Not Retrieved Reactor Internals Disconnect Device * Unit I RCB .Not Retrieved Feedwater Booster Pump Motor Unit I TGB Not Retrieved Feedwater Booster Pump Unit I TGB Not Retrieved Steam Generator Feed Pump Unit I TGB Not Retrieved Diesel Generator Unit I DGB Not Retrieved Spent Fuel Pool Skimmer Unit I FHB El 27 Not Retrieved Load Center E1C-1 Unit I MEAB El 65 Not Retrieved Chemical and Volume Control Monitor Unit I MEAB El 35 Not Retrieved Relay Cabinets Unit I MEAB El 35 Not Retrieved Pressurizer Heater Controller Unit I MEAB El 35 Not Retrieved

'2" Carbon Steel Pipe Spoo1* Unit I MEAB El 46 Not Retrieved Radwaste Holdup Tank * Unit I MEAB El 57 Not Retrieved Load Center Transformers Unit I MEAB El 10 Not Retrieved Liquid Waste Pumps Unit I MEAB El 10 Not Retrieved Essential Cooling Water Pump Unit I MEAB El 10 Not Retrieved

"Except for those items indicated by an asterisk, the NRC CAT inspector requested documentation to determine bolting requirements. Since documentation was not provided, traceability was not verifie VI-11

TABLE VI-7

.

ELECTRICAL EQUIPMENT BOLTING

!

Item Location- Compliance Relay' Rack Cabinets Unit I MEA 8 El 35 Unsatisfactory Computer Unit I MEAB El 35 Satisfactory

'

Pressurizer Heater-Controller Unit I MEAB El 35 Unsatisfactory Load Center Transformers Unit I MEAB El 10 Unsatisfactory Battery Racks Unit I MEAB El 10 Unsatisf actory Battery Racks Unit I MEAB El 35 Unsatisfactory Battery Racks Unit I MEAB El 65 Unsatisfactory C&VC Control Board Monitor Unit I MEAB El 35 Unsatisfactory Bi-Stable Status Control Board Monitor Unit I MEAB El 35 Unsatisfactory Load Center Transformers Unit I MEAB El 65 Unsatisfactory Diesel Generator. Control Panels Unit I DGB El 35 Unsatisfactory l

!

i

< VI-12 l

l =-

,

TABLE VI-8 MECHANICAL BOLTING Item Location Compliance Chilled Water Pump Unit II MEAB El 10 Unsatisfactory Centrifugal Charging Pump Unit II MEAB El 10 Satisfactory Charging Pump Gearbox Unit II MEAB El 10 Unsatisfactory Positive Displacement Charging Pump Unit II MEAB El 10 Satisfactory Recycle Evaporator Feed Pump Unit II MEAB El 10 Satisfactory ECW Wash Screen Pump ECW Building Satisfactory ECW Wash Screen Motor ECW Building Unsatisfactory FCW Motor ECW Building Satisfactory Fire Pump Fire Pump House Unsatisfactory RHR Pump Support Unit 1 RCB El 3 Satisfactory Feedwater Booster Pump Unit 1 TBG Unsatisfactory Steam Generator Feed Pump Unit 1 TGB Unsatisfactory Auxiliary Feedwater Pump Unit I Valve Cubicle 1 ' Satisfactory Auxiliary Feedwater Motor Unit I Valve Cubicle 1 Unsatisfactory Diesel Air Compressor Unit I DGB Unsatisfactory Fire Protection Actuators Unit I Deluge House #12 Unsatisfactory Spent Fuel Cooling Pump Unit I FHB El 35 Satisfactory HHSI, LHSI & Containment Spray Pumps (9) Unit I FHB El 15 Unsatisfactory HHSI, LHSI & Containment Spray Motors (9) Unit.I FHB El 15 Unsatisfactory Spent Fuel Pool Skimmer Unit I FHB El 27 Unsatisfactory Liquid Waste Pump Unit I MEAB El 10 Unsatisfactory ECW Turbine Driver Unit I Valve Cubicle 4 Unsatisfactory VI-13

VII. DESIGN CHANGE CONTROL

' 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 commitments and approved licensee, engineer, constructor and vendor procedures. An additional objective was to determine that the changes.to structures and hardware prescribed in a sample of design change documents were accurately complete 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 Rev. 2, June 1976, " Quality Assurance Requirements for the Design of Nuclear Power Plants," which endorses American National Standards Institute (ANSI) Standard N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants." The licensee's commitments to comply with RG 1.64 is stated in Chapter 17 of the South Texas Project (STP) Final Safety Analysis Report (FSAR).

The areas of design change control evaluated by the NRC Construction Appraisal Team (CAT) inspectors were control of changes to design documents and control of design changes. In each of these areas, interviews were conducted with persor.nel responsible for the control of activities, procedures were reviewed, and a sample of the controlled documents was reviewed. In addition, a sample of the completed structures and hardware which had been inspected and accepted by on-site contractor quality control (QC) personnel was inspected by the NRC CAT inspectors. These evaluations were performed on an interdiscipline basi . Control of Design Documents The specific aspects of the control of design documents inspected were the availability to the users of the latest approved design documents and design change documents, and the methods of assuring that approved changes not yet incorporated into design documents are provided to the users prior to work being performed, Inspection Scope (1) The following general quality assurance (QA) program manuals and procedures primarily related to distribution and control of design documents and design change documents were reviewed to establish the acceptance criteria for this portion of the inspection:

'

Houston Lighting and Power Company (HL&P) Project Quality Assurance Plan for South Texas Project, Rev. 7, dated August 7, 198 VII-1

]

Bechtel South Texas Project Quality Program Manual, Rev. 3, dated July 15, 198 *

Ebasco Nuclear Quality Assurance Program Manual ETR-1001 for South Texas Project, Rev. 12, dated July 26, 198 *

South Texas Project Procedure No. RMSP 1.02, " General Operating Description-RMS," Rev. 3, dated August 1, 198 *

South Texas Project Procedure No. RMSP 2.03, " Design Drawing and Drawing Change Notice Control," Rev. 3, dated June 14, 198 *

South Texas Project Procedure No. RMSP 2.05, " Specifications, Specification Change Notices and Procurement Document Control,"

Rev. 4, s ted March 14, 198 *

South Texas Project Procedure No. RMSP 3.16, " Quality Records," Rev. 6, dated May 20, 198 '

Bechtel Procedure No. WPP 3.0, " Field Control of Design

' Documents," Rev. 17, dated November 13, 198 *

Bechtel . Procedure No. WPP 3.2, " Field Supplier Document Control," Rev. 3, dated March 29, 198 *

Bechtel Procedure No. WPP-QCI 6.0, " Control, Review and Processing of Quality Records," Rev. 9, dated March 25, 198 *

! Bechtel Engineering Department Procedure (EDP) No. 4.46,

" Project Drawings," Rev. 8 STP, dated March 6, 198 *

Bechtel EDP 4.49, " Project Specifications," Rev. 6 STP, dated January 23, 198 *

l Ebasco Quality Assurance Instruction (QAI) No. 019, l " Review, Processing and Turnover of Quality Records,"

Rev. 2, dated March 25, 1985.

'

Ebasco Quality Control' Procedure (QCP) No. 6.2, " Document Control," Rev.1, dated January 21, 1985.

t

Ebasco QCP No. 17.1, " Quality Assurance Records," Rev. 3, dated March 8, 198 *

Ebasco Procedure No. ASP-6, " Document Control," Rev. 7, dated May 17, 198 (2) Bechtel, Ebssco and HL&P QA audit and surveillance reports concerning det.ign document control were reviewed for findings, trends and corrective action VII-2

_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

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

4

' (3) Bechtel, Ebasco and HL&P document control, engineering, 1 construction and QA personnel were interviewed concerning

design document and design change document distribution and contro b. -Inspection Findings i

(1) Design documents and design change documents are issued by  :

Bechtel; issue at the site is through the Bechtel Field  !

Document Control Center (FDCC) to various satellite document stations in accordance with a distribution matrix. The

satellite stations are also controlled by Bechtel. A.compu-i terized Field Revision List (FRL) is the data base which gives i the current design document revision and lists the unincor- f i

'

porated design changes; a " historical" version of the FRL' ,

showing each revision of design documents and the change

'

documents written against each revision is also availabl The unincorporated design changes are posted on the design documents in the reference stations to relieve the users of i the need to review the FRL.

. i

(2) The NRC CAT inspectors reviewed against the latest FRL a series of procedures, specifications and drawings at the Bechtel FDCC, at Bechtel Reference Station A02 (located in the Unit 1 con-struction office, Building 10), and at Bechtel Reference

Station B49 (located in the Unit 2 construction office, Building 16). Tables VII-1A through IE summarize the NRC ,

CAT findings for this review, which was performed to check  :

that documents were being distributed, posted and otherwise

~

controlled in accordance with Bechtel Procedure WPP 3.0,

" Field Control of Design Documents, and other applicable requirements.

The team reviewed eleven Bechtel and Ebasco procedures and five Bechtel specifications against the latest FRL at Reference

- Station A0 Four of the sixteen documents had deficiencies (i.e. , did not accurately reflect all approved changes) as recorded in Table VII-1A.

<

Fifteen Bechtel large and small bore piping' isometric drawings '

'

.

were reviewed at Reference Station A02. The active change documents listed in the field revision log for these drawings were posted on the drawings with minor exception, and only a few superseded change documents were found posted on the drawings (Table VII-1B).

.

4 A total of 49'Bechtel electrical drawings.were reviewed

. against the latest FRL at Reference Stations A02 and B49 i (Tables VII-1C-D). Four of the nineteen drawings reviewed at

Reference Station B49 exhibited an unacceptably high rate of '

discrepancies (Bechtel drawings 3E359E58020, -029, -191 and

,

-317, Table VII-10). The NRC CAT inspectors are particularly concerned about the active change documents not posted on the drawings, since this information is lost to the users. These

drawings were all cable tray support detail " cookbook"

'

<

VII-3 L

+ --m,,,m+-----e-. ,-e, , , - - , , m-,r- * -.-- - ~ + -.m., ,--y , + - - ew -

F drawings. The cable tray support " cookbook" drawings posted in the reference stations are maintained by reference station personnel for reference use only. However, FDCC maintains the master copies of these drawings, and issues bound sets of these detail drawings at five-day intervals to check-out-stations where their issuance for use by the construction craft is also controlle In order to determine if incorrect information was being issued to the construction crafts, the team reviewed 21 electrical drawings at the Bechtel FDCC against the latest field revision log, including 11'of the detail drawings reviewed at Reference Station B49. The team found these drawings to be properly controlled (Table VII-1E).

(3) The NRC CAT reviewed a sample of ten pipe support detail drawings for large and small bore safety class pipe. The latest issue of each pipe support drawing was checked to confirm that any change documents issued against the previous revision to the drawing had been properly incorporated. No discrepancies were observe (4) A Bechtel in-house study entitled " Overview of the Design Change Control Program" was prepared at the request of the NRC CAT inspectors and issued on November 11, 1985. This study describes the scope and trends of change documents issued for the South Texas Project, as well as compliance with respect to the number and time constraints detailed in existing site procedures; i.e., documents must be revised every "x" months or when "y" unincorporated design changes are outstandin Attachment C, sheet 2 of the study indicates, for example, that a total of 25,320 Drawing Change Notices, 27,120 Field Change Requests, and 4,113 Field Change Notices have been issued for the South Texas Project through October, 1985. Attachments H, sheets 1, 2 and 5, indicate that approximately 90 percent of the change documents tracked since the beginning of 1985 have been processed in accordance with the governing number and time constraint c. Conclusions The controls for posting unincorporated design changes on design documents were not adequately implemented at Station B49. However,.

for the sample inspected, the availability of design documents and approved design change documents for users is generally adequat . Preparation of Document Packages The use of design documents and design change documents in the preparation of work packages and inspection packages was inspecte VII-4 Inspection Scope (1) The following procedures primarily related to the preparation and use of work packages and inspection packages and were reviewed to establish the inspection criteria for this portion of the inspection:

South Texas Project Standard Site Procedure (SSP) No. 36,

" Work Package Control," Rev. O, dated September 16, 198 *

Bechtel QCP-10.16, " Inspection of Electrical Raceways,"

Rev. 4, dated May 1, 198 *

Bechtel PED-027, " Civil / Structural Directive for the Review of Pipe Support Drawings," Rev. 1, dated March 13, 198 *

Bechtel Specification 3A010SS0012 for Category I Structural Steel, Rev. 2, dated January 21, 198 *

Bechtel Specification 3A010SS0026 for Category I Miscellaneous. Steel, Rev. 6, dated August 27, 198 *

Ebasco QCP-9.5, " Weld Inspection (AWS)," Rev. 6, dated October 10, 198 *

Ebasco QCP-10.5, " Inspection of Structural Steel Erection and Bolting," Rev. 5, dated July 19, 198 *

Ebasco QCP-10.7, " Miscellaneous Metal Fabrication," Re , no rev. dat *

Ebasco QCP-10.12 " Component Support Fabrication and Installation Inspection," Rev. 4, dated June 17, 198 *

Ebasco QCP-10.19, " Inspection of Anchoring Devices Installed Within Concrete Structures," Rev. 6, dated February 28, 198 *

Ebasco QCP-10.31, " Inspection of Configuration Control Packages," Rev.1, dated July 11, 198 *

Ebasco Procedure Construction Site Procedure (CSP) 43,

" Installation of Electrical and Associated Hangers,"

Rev. 5, dated September 30, 198 (2) Bechtel, Ebasco and HL&P document control, engineering, construction and QC personnel were interviewed concerning the use of design documents and design change document VII-5

-

-

.

b. -Inspection Findings (1) Ten samples of installed structural _ steel installation docu-ments and QC inspection records provided by Ebasco civil /

structural site engineering were reviewed. Table VII-2 summarizes the NRC CAT findings for this review, which was performed to confirm that Ebasco used the correct drawings, change documents, procedures and specifications to install and inspect the structural. steel. Four of the ten samples were found_to have deficiencies. The most significant. finding from this review was that work done under a Field Change Request (FCR) dated September 14, 1984 had not been QC. inspecte When a QC inspection was performed, a nonconformance was identified (Item 1, Table VII-2).

Structural steel is installed and inspected based on design drawings and approved design changes (i.e., there is no procedural requirement at STP for a structural steel work package) and the related QC inspection activities are performed on an area basis, with no easily auditable tracking of. records for specific joints, members, etc. In a number of instances, the team encountered difficulty in identifying the specific-installed steel that had been QC inspected. As a consequence, some installed or modified structural steel may not be Q inspected or inspected in a timely manne On September 20, 1985, HL&P notified NRC Region IV of a potentially reportable. item ccncerning inspection of installed structural steel. The lack of an accurate detailed location description for structural steel is one of the identified deficiencies currently under review by NRC Region IV. The licensee is conducting an investigation to determine the extent of the documentation deficiencies in regard to structural steel erection. A thorough review of inspection documentation on structural steel erection is currently being performed. The licensee's review should also address the above identified NRC CAT findin (2) A sample of installation documents and QC inspection records for the ten electrical cable tray supports listed in Table VII-3A was reviewed to verify that Ebasco used the correct drawings, change documents, procedures and specifications to install and inspect the cable tray hangers. Table VII-38-summarizes the NRC CAT findings for this review. Minor docu-mentation deficiencies were identified in seven of the ten sample There is no requirement at South Texas Project to provide an

- as-built record of an installed cable tray suppor In addi-tion, a given cable tray support detail drawing defines a design envelope rather than a unique hanger configuration. As a consequence, physical inspection is required to verify the specific configuration of an installed cable tray suppor NRC CAT inspectors verified another sample of 14 cable tray supports, and concluded that the installed hanger configurations VII-6

conformed to the hanger detail drawing NRC CAT review of this sample is documented in Section II, Electrical and Instrumentation Construction, of this report.

c. Conclusions The use of design documents and design change documents in prepara-tion of work packages and inspection packages appears generally adequat However, during this review a deficiency in inspection of structural steel was identified. The licensee needs to determine whether this deficiency will be addressed in his overall evaluation of the inspection of structural steel pursuant to his notification to NRC Region IV of similar problems with the inspection and iden-tification of structural steel.

3. Control of Design Changes The specific aspects of the control of changes to design inspected by the NRC CAT were the change control systems for Field Change Notices (FCNs), Field Change Requests (FCRs) and Drawing Change Notices (DCNs) and implementation and verification of the changes.

a. Inspection Scope (1) The following procedures relating primarily to the control of design changes were reviewed to establish the acceptance criteria for this portion of the inspection:

South Texas Project Site Instruction 2.17, " Requests for Engineering Assistance," Rev. 2, dated July 31, 198 *

Bechtel Procedure No. WPP-QCI 20.0, " Field Change Request,"

Rev. 15, dated August 20, 198 *

Bechtel Procedure No. WPP 20.1, " Field Change Notice,"

Rev. 5, dated May 21, 198 *

Bechtel Procedure No. WPP 22.0, " Configuration Control Package (CCP)/(Design Change Package - DCP)," Rev. 2, dated November 4, 198 *

Bechtel Procedure No. WFP-QCI 34.0, " Organization and Responsibilities," Rev. 8, dated June 10, 198 '*

Bechtel EDP-2.13, " South Texas Project Engineering Team Organization and Responsibilities," Rev. 4 STP, dated June 1, 198 *

Bechtel EDP-4.26, " Interdisciplinary Design Review,"

Rev. O, dated December 2, 197 *

Bechtel EDP-4.27, " Design Verification," Rev. 2 STP, dated July 31, 198 VII-7

_ _ _ _ _ _

Bechtel EDP-4.33, "On-Project Design Review," Rev. 3 STP, dated December 31, 198 *

Bechtel EDP-4.34, "Off-Project Design Review (Design Control Check List and Design Review Notice)," Rev. 2 STP, dated December 15, 198 *

Bechtel EDP-4.37, " Design Calculations," Rev. 4 STP, dated August 7, 198 *

Bechtel EDP-4.47, " Drawing Change Notice," Rev. 4 STP, dated February 6, 198 *

Bechtel EDP-4.62, " Field Change Request / Field Change Notice," Rev. 5 STP, dated March 26, 198 *

Bechtel EDP-4.72, " Configuration Control Package,"

Rev. 3 STP, dated September 5, 198 *

Bechtel EDP-4.73, " Design Change Management Procedure (Design Change Approval Request - DCAR - Process),"

Rev. 2 STP,. dated May 23, 198 *

Ebasco Procedure No. ASP-7, " Field Change Notice Procedure,"

Rev. 4, dated August 1, 198 *

Ebasco Procedure No. ASP-11 " Field Change Request," Rev. 4, dated July 29, 198 *

Ebasco Procedure No. ASP-17, " Configuration Control Package (CCP)/ Design Change Package (DCP)," Rev. 2, dated October 28, 198 (2)' Bechtel and Ebasco QA audit and surveillance reports concerning design changes were reviewed for findings, trends and~ corrective action (3) Interviews were conducted with personnel from Bechtel, Ebasco and HL&P concerning initiation (organization) review, approval and implementation of design change b. Inspection Findings (1) The Bechtel Site Engineering Organization (SE0) currently employs approximately 150 office personnel and 120 field personnel on site. The functions of Bechtel SE0 are described in Bechtel procedure.WPP-QCI 34.0, subsection The functions of Bechtel project engineering personnel assigned to the site are described in Bechtel procedure EDP 2.13, l subsection 5.6. Bechtel project engineering personnel assigned to the job-site take the lead in responding to field

, change requests, provide engineering dispositions on noncon-L

'

formance reports, and monitor Ebasco field change' notices for compliance to Ebasco and Bechtel requirements.

l VII-8

<

(2) The NRC CAT reviewed a sample of 55 Bechtel and Ebasco FCNs, l FCRs and DCN These change documents ,

were selected from the civil / structural and pipe support disciplines. Table VII-4 summarizes the NRC CAT findings derived from this review, which was performed to confirm that change documents had been correctly incorporated into the referenced drawings. .NRC CAT review of an additional sample of design change documents is discussed in Section VII.B.3.b.(7), belo Discrepancies were observed in the incorporation of 8 of the 55 change documents into the design documents. In seven cases, the team found that either the technical content or the scope of some change documents had been modified upon'

incorporation into the referenced design drawing Six of these. cases involved modification of FCRs or FCNs. Neither Bechtel procedure WPP-QCI 20.0, " Field Change Request,"

subsection 5.4.3, nor Ebasco procedure ASP-11, " Field Change Request," subsection 8.0.6, permits the modification of Field Change Request Bechtel procedure EDP 4.47, " Drawing Change Notice," subsection 3.6 permits the modification of a Drawing Change Notice upon incorporation into a design drawing, if notification is included in the drawing revision block.

'

However, the change documents are not annotated to indicate the modified version of the technical content or scope that has been incorporate Change documents originally restricted to k 2ilation in either Unit 1 or Unit 2 have been modified upon incorporation into the. referenced drawing for installation in both Unit Since many drawings are applicable to both Units 1 and 2 by default, and since the change documents are not reviewed to reflect the incorporated modification, it is not possible to determine if any error of omission has occurred or a conscious design decision has been mad (3) The NRC CAT reviewed selected audits in the area of design control (Table VII-5) that had been conducted either by Bechtel or Ebasco, or by teams composed of Bechtel, Ebasco and HL&P personnel. The modification of some field change requests upon incorporation into the design drawings does not appear to have been an identified concern, although Bechtel explicitly audited this attribute in the latter part of 1984 (audit No. ESI-14-84, page 45, audit item 47).

The team also reviewed audit findings with respect to the Bechtel/ Westinghouse interface. Audit M24-501 was conducted on March 11-25, 1984 to assess the programmatic adequacy and the proper procedural implementation of the Westinghouse NSSS program on site. The audit summary noted that the corporate Westinghouse program was being adequately implemented, but concluded that' site specific procedures and instructions had not been developed to control. activities affecting quality which were being performed by Westinghouse site personne VII-9

_ -

-

The audit summary considered this a significant deficiency which could have an impact on the overall South Texas Project quality program. Audits S15-501, D08-501, G42-501 and S23-501 also address aspects of the Bechtel/ Westinghouse design interface. The deficiencies identified in Section II, Electrical and Instrumentation Construction, of this report with respect to the installation of Westinghouse motor operated valves indicate that the concerns identified in previous audit reports at the Bechtel/ Westinghouse design interface require vigorous corrective action to assure a controlled A/E-NSSS design interface at South Texas Projec (4) The NRC CAT documented conflicting definitions for confi-guration control package revisions in the governing Bechtel and Ebasco procedures: Bechtel EDP 4.72, subsections 7.3-4; Bechtel WPP-22.0, subsection 4.9.1, and Ebasco ASP-17, subsec-tion 8.0.4. One definition notes that each revision of a configuration control package supersedes all previous revi-sions, and includes all previously issued design informatio Another definition notes that each revision of a configuration control package supplements the previous revisions, and that all revisions are necessary to determine the intended final installed configuration. Design documents contained in a specific configuration control package may be revised upon completion of the physical work associated with that packag The team notes that the Bechtel field document control center has recently upgraded -the field revision list to identify con-figuration control packages as a function of a given drawin However, the NRC CAT is concerned that drawings incorporated into multiple configuration control packages prior to this upgrade may have been subject to conflicting modification (5) The NRC CAT requested the Bechtel structural calculations for ten civil / structural change _ documents which added (or modified) equipment support steel to the Bechtel structural drawings. Table VII-6 summarizes the NRC CAT findings for this review, which was perfonned to confirm that appropriate calculations had been performed to substantiate design changes to project drawings. The team found seven of the ten Bechtel calculations acceptabl Three of the changes . reviewed were found to have inadequate

. calculational bases. A calculation for a nonsafety support in the seismically designed Fuel Handling Building had been performed, but not checked or signed off by a group leader (Table VII-6, item 1). Four bays of floor steel had not been verified by calculation, or by documented engineering judgment (Table VII-6, item'2), and some existing steel that was recently checked for the first time showed relatively high stress ratios (Table VII-6, item 3).

The NRC CAT is concerned that structural calculations or other adequate documentation of design bases may be lacking for some structural steel in safety related and nonsafety seismic structures. All structural steel should be explicitly or VII-10

generically qualified, and this analytical qualification should be documente ANSI N45.2.11-1974 Section 4.2, Design Analyses, notes in-part that " Analyses shall be sufficiently detailed as to purpose, method, assumptions, design input, references and units such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without recourse to the originator."

(6) The NRC CAT reviewed three pipe support calculations to verify that supplementary steel had been properly ~ modeled, and that calculated weld sizes had been noted on the pipe support drawings. Although no concerns were identified, the team had become concerned during the course of the inspection that pipe support supplementary steel and supporting steel was not always being evaluated for possible addition of beam stiffener plate However, the NRC CAT was informed that a pipe support review team has already been established within the Bechtel pipe support group to review all ASME and seismic II/I supports for various pipe support design attributes. Both new as well as existing pipe support designs will be reviewed under this program, in accordance with Rev. 3 to Bechtel PED 02 (7) Inspectors in each NRC CAT discipline checked the design con-trol process at South Texas Project by evaluating compliance of a sample of installed and inspected hardware with respect to the applicable design drawings and their approved design change documents (Table VII-7A-C). In most instances,.the installed hardware conformed to the design documentatio .0f the 87 hardware samples reviewed for compliance with the governing design change documents, only 2 discrepancies were note However, because the NRC CAT is concerned that the design control process at South Texas Project may not be adequately controlled in some areas, i.e. , motor-operated valves (Section II.B.3.b(8)), the licensee needs to assess the

impact that these deficiencies may have on the associated hardwar c. Conclusions Control of the design change process is generally adequate for the sample inspected. However, additional management attention is needed to: (1) preclude further modification of design changes during incorporation into their referenced drawings, particularly unit specific changes, (2) control the design interface between Bechtel and Westinghouse, (3) ensure that documented calculations exist to demonstrate both the bases and adequacy of design drawings and design changes, and (4) to ensure that the conflicting defi-nitions for configuration control packages have not resulted in the improper use or as-building of these change document VII-11

, - . _-- - - -

I TABLE VII-1A

REVIEW 0F POSTING OF DESIGN CHANGES PROCEDURES / SPECIFICATIONS SAMPLE Reference Station A02 Documen Observation Ebasco Procedure a) Table of contents does not list ICP ASP-11 (interim change to a procedure) No. 1; b) Procedure pages not correctly numbered Ebasco Procedure Table of contents does not list PCR QCP-1 (procedure change report) No. 7 Bechtel Specification a) Table of contents and appendices SA010PS002 misfiled; b) Total number of pages per appendix not tabulate Bechtel Specification Total number of pages per appendix not 3A010SS0030 tabulated

,

VII-12

--

TABLE VII-1B REVIEW 0F POSTING OF DESIGN CHANGES BECHTEL LARGE AND SMALL BORE PIPING ISOMETRIC SAMPLE Reference Station A02 Total Active Superseded Change Documents Active CDs Not CDs Posted Drawing Sheet N Rev. N ,

(CDs) Posted on dwo On dwa

'8M369 PIA 239 A08 4 5 - -

8M369 PIA 239 A13 4 4 - -

-

8M369 PIA 239 A17 4 4 - -

8M369 PIA 239 A24 3 4 - -

8M369 PIA 239 A29 4 3 - -

3M369PCC207 2 4 17 - -

SM369PCC207' S 3 5 - -

SM369PCC207 7- 4 14 1 -

4M369PCC207 9 5 14 - -

5M369PCC207 10 4 18 - -

3M369 PEW 229 18 0 40 1 -

-50369 PEW 329 5 1 18 -

3C01951542 -

4 6 -

3C019S1600 -

5 2 - -

3C01951603 -

3 3 1 -

TOTAL F 3- 3 VII-13

_-

TABLE VII-1C REVIEW OF POSTING OF DESIGN CHANGES BECHTEL ELECTRICAL DRAWING SAMPLE Reference Station A02 Total Active Superseded Change Documents Active CDs Not- CDs Posted Drawing Sheet N Rev. N (CDs) Posted on dwg On dwg-3E560E55127* -1 1 21 '- -

-3E359E58001' 1 11 7 -

3E359E58001 4 6 4 -

3E359E58001 -5 7 4 --

3E359E58001 7 4 7 -

3E359E58001- 2 9 2 -

-3E359E58002 1 0 3 - -

SE209E01638 2 9 5 - -

SE209E1631- ~

5 8 3 - -

.9E0VNAV.- 1 3 6 - -

9EEWO101- 1 2 5 -

li 9E0HE21 1 2 2 - -

SE549EL5031 -

8 15 - --

~3E209E2825 -

8 16 - -

3E209E56009 -

9 7 > - -

9E0ANO3 2 2 1 - -

6E100E02130- -

.7 6 - -

SE030E0100 3 14 4 - -

9E00AAB 1 5 1 - -

.5E030E010 A 3 4 - -

-9E0HC09 1 2 2 - -

SE500E00103 .3 22 9 2 -

9E0VCAB 1 3 5 - -

9E0VCAG 1 2 3 1 -

9EOFP08 1 3 -4 - --

-9EOPMAL 1 5 3 - -

OEOSW10 - 1 1 2 - -

3E209E56104 -

5 6 - -

9EOPFCF 1 3 2 - -

1EPFCC01' 1 3 1 - -

TOTAL T6T 3 T (*) There were approximately 35 not to be incorporated (N/I) CDs posted on this drawing that were subsequently tabulated on sheet 1A of the drawing and should have been deleted from sheet (!) Incorrect CD No.-poste VII-14

TA8LE VII-1D-REVIEW OF POSTING OF DESIGN CHANGES BECHTEL ELECTRICAL DRAWING SAMPLE Reference Station B49 Total Active Superseiled Change Documents Active CDs Not CDs Posted Drawing Sheet N Rev. N (CDs) Posted on dwg On dwg 3E359E58317 1 5 14 3 5

- -3E359E58191 1 3 4 1 6 3E359E58020 1 10 15 9 4 3E359E58029 1 6 7 2 5 3E359E58260 1 6 6 - -

6E210E02564 2 4 6 -

3E359E58042 1 11 9 1 2 3E359E58140 1 4 7 - -

9E560E50021 -

3 4 -

3E359E58901 1 1 5 -

it 3E359E58067 1 '5 7 2- -

3E560E55127 l' 1 21 - -

3E560E55127 1A 2 E359E58822 1 4 13 -

-3E359E58072 1 6 5 - -

3E359E58041 1 9 10 1 1 SL49T60002 '

-

16 44 16 1 3E560E55045 -

12 15 - -

.3E560E55046 -

-9 22 -

TOTAL 717~ 20 -'2T (1) Incorrect CD posted (9) 1 CD posted on drawing.twice

. VII-15

_ , . _ - _ _ ._ ,

.

TABLE VII-1E REVIEW 0F POSTING OF DESIGN CHANGES

. BECHTEL ELECTRICAL DRAWING SAMPLE Field Document Control Center (FDCC)

Total Active Superseded Change Documents' Active CDs Not. CDs Posted Drawing Sheet N Rev. N (CDs) Posted on dwa On dwg

.3E359E58317* 1 5 14 lt

-

3E359E58191* 1 3 4 - -

3E359E58020* 1- 10 15 1 -

3E359E58029* 1 6 7 - -

3E359E58041* 1 9 10 - -

3E359E58140* 1- 4 7 - -

3E359E58148 1 6 3 - -

3E359E58169- 1 5 3 - -

3E359E58238 1 3 3 - -

3E359E58093 1 4 4 1 -

3E359E58260* 1 6 6 - -

3E359E58268 1 2 3 - -- '

3E359E58048 1 8 3 - -

3E359E58057 1 4- 3 -

3E359E58901 1 1 5 - -

3E359E58831 1 1 2 - -

3E359E58042* 1 11 9 - -

.30359E58067* 1 5 7 - -

3E359E58073 1A 5 4 - -

3E359E58072* 1 6 5 - -

-3E359E58822* 1 4 13 -

TOTAL 130 3 2

.

(*) Drawings reviewed at Reference Station B49 ( ) 1 CD number transposed VII-16

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

,

-

TABLE VII-2 REVIEW OF WORK PACKAGES AND INSPECTION REPORTS STRUCTURAL STEEL SAMPLE

'

ITEM- OBSERVATION -

<

1 Field Change Request (FCR) No. CC-0414W was issued on September 14, 1984-against Bechtel drawings No. 3C01-9-S-1506, Rev.:5,

3C01-9-S-1508, Rev. 3, and 3C01-9-S-1510, Rev. 2. The.FCR

.specified the coping of radial and circumferential steel at three

different elevations in containment. Coping the beam.

,

'

flanges provides access to enable welding of the containment liner plate at the construction hatch opening. -However, at the time of the CAT inspection, the steel rework had not been QC inspecte Subsequent Ebasco-QC inspection is documented on miscellaneous

, metal fabrication inspection report 3461F1 dated October 28, 1985. Nonconformance Report Number CC-03133 was also issued on

~

f'

October 28, 1985 to document coping of beam flanges in excess of

,7 the dimensions specified in the FCR.

i 2 Drawing Change Notice (DCN) No. 3 was issued on January _25,1985

, against Bechtel drawing No. 3F01-9-S-3001, Rev.1, in order to

,

. provide support details for Fuel liandling Building Sump Tank N Sump Pumps 9Q061/2NPA113 Field Change Notice (FCN) 1-C-0329 provides the fabrication details for the new stee However, there are discrepancies in the bolt hole diameters specified for-

,_ the beam clip angles. The DCN and the drawing sp?cify 15/16 in.

. diameter bolt holes for 3/4 in. diameter bolts,:while the FCN-r- specifies 13/16 in. diameter bolt holes. The Bechtel civil /

structural site engineering organization issued DCN No. 5 on Octobe'r 30, 1985 to correct DCN.No. 3.

. 3 FCR BC-01544 was issued on December 24, 1984 against Bechtel

. drawing No. 3F01-9-S-3005, Rev.1.1 The FCR detailed modifica-

~

i tions to'HVAC plenum No. 9V121VXV021 perimeter grating and u support steel to provide an air-tight sea However, Ebasco QC AWS D1.1 structural welding inspection report No. 1-00865,-dated

{. Narch 7, 1985, incorrectly references Rev. 1 of the Bechtel drawing. Rev. 2 of the drawing, dated December 18, 1984, was the correct drawing of record. The inspection report was

,

corrected on October.30, 198 t 4 The not to be incorporated (N/I) amendment list for Bechtel drawing .3M01-9-S-4043, Rev. 3, dated July 15, 1985, incorrectly references FCN 1C-0265, dated February 21, 1985, as a FCR.

L Rev. 4 of the drawing, issued on November 5, 1985, correctly

!

references the FCN.

i.

l VII-17

,

[

TABLE VII-3A LISTING OF ELECTRICAL CABLE TRAY SUPPORTS

~ Support N Location Drawing N H64- 3-E-20-9-E-56004, Rev. 3 H117 3-E-20-1-E-56004, Rev. 5 H2 3-E-35-9-E-56008, Rev. 8 H153 3-E-20-9-E-56004, Rev. 3 H139 3-E-35-9-E-56008, Rev. 5 H115 3-E-20-9-E-56004, Rev. 3 H84 3-E-20-1-E-56004, Rev. 5 H136 3-E-35-9-E-56008, Rev. 3 H102 3-E-35-9-E-56008, Rev. 5 H100 3-E-35-9-E-56008, Rev. 8

.

VII-18 j l

TABLE VII-3B REVIEW 0F WORK PACKAGES AND INSPECTION REPORTS ELECTRICAL CABLE TRAY SUPPORT SAMPLE-ITEM OBSERVATION 1 Page 2 of the electrical' raceway hanger inspection record / traveler for hanger No.1-004-H64 does not reference Bechtel drawing No. 3-E-35-9-E-58140, sheet 1, Rev. 2 AWS D1.1 structural welding inspection report No. 02630 for hanger No. 1-004-H64 does not reference the cable tray hanger connection detail drawings, and references incorrect detail numbers 22 and 23 for the installed cable tray. ~The correct details are 42 and 7 The inspection report was corrected on November 11, 198 Bechtel drawing No. 3-E-20-1-E-56004, Rev. 5, is incorrectly referenced on page 3 of the electrical raceway hanger inspection record / traveler for hanger No. 1-004-H117. The inspection report was corrected on November 11, 198 Page 2 of the electrical raceway hanger inspection record /

traveler for hanger No.1-004-H153 does not reference Bechtel drawing No. 3-E-35-9-E-58148, sheet 2, Rev. AWS D1.1 structural welding inspection report No. 02407 for hanger No.1-004-H153 references Rev. 2 of Bechtel drawing 3-E-20-9-E-56004. Rev.-3 of the drawing, dated September 16, 1983, was the drawing of record at the time of inspection on October 20, 1983. The inspection report was corrected on November 11, 198 AWS D1.1 structural welding inspection report No. 02407 does not reference the cable tray hanger connection detail drawing Page 2 of the electrical raceway hanger inspection record / traveler for hanger No. 1-008-H139 does not reference Bechtel drawing N E-35-9-E-58029, sheet 4, Rev. The line diagram for the cable tray support shown on page 2 of the electrical raceway hanger inspection record / traveler for hanger No. 1-004-H115 shows one more G58HD12A tray support than the installed cable tra Page 1 of the traveler (item 5) does not reference Bechtel drawing No. 3-E-35-9-E-58117, sheet 3, Rev. 5. The inspection report was corrected on November 11, 198 Page 2 of the traveler (item 5) does not reference Bechtel drawing No. 3-E-35-9-E-58117, sheet 3, Rev. VII-19

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

,.; TABLE VII-3B - (Continued)

9 REVIEW OF WORK PACKAGES AND INSPECTION REPORTS j ELECTRICAL-CABLE TRAY SUPPORT SAMPLE ,

ITEM OBSERVATION AWS D1.1-structural welding inspection report No. 02630 for hanger No. -1-004-H115 does not reference the cable tray hanger connection

. ~ detail drawings. The inspection report was corrected on November

'll', 198 :

].

,

6 Page 2 of electrical raceway-hanger inspection record / traveler-1-004-H84, prepared on December 19,-1983, was not updated to reference Field' Change Request (FCR) CE-02312, dated April 24, .

, 1984. The construction supervisor signed off on page 2 on June 23, 1985.

'

7- Page 2 of the electrical raceway hanger inspection recor'd / traveler-

for hanger No.1-008-H136 references Field Change Notice (FCN)

CE-0083 The change document is actually a FCR. Ebasco voided

-

this FCR on January 6, 1984. The construction supervisor signed

>

off page 2 on August 4, 198 FCR CE-00923 is referenced on the traveler (item 7). However, this FCR was superseded by FCR CE-01089 on November 4,198 FCR CE-01089 is referenced on page 2 of the traveler, but does not appear to be applicable to hanger 1-008-H136.

-

FCR~CE-00578 is referenced on the traveler (item 7), but this FCR was superseded by FCR CE-00828 on September 27, 1983, which is not referenced on the travele FCR'CE-01133 is referenced on the traveler (item 7) but this FCR

-

was superseded by FCR CE-01287 on December 6, 1983, which is not

,

referenced on the travele Page 5 of electrical raceway hanger inspection record / traveler N H136 does not reference Bechtel drawing 3-E-35-9-E-58042,

'

.

sheet 5; Rev. The inspection report was corrected on November 11, 198 ,

l VII-20 l

i 1

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

TABLE VII-4 I REVIEW OF DESIGN CHANGE DOCUMENTS FOR INCORPORATION INTO DESIGN DOCUMENTS j

ITEM OBSERVATION 1 Field Change Request (FCR) BC-01202 was issued on June 13, 1984 against Rev. 2 of Bechtel drawing 3M01-9-C-4312. The FCR was issued to reduce an oversized HVAC opening. A modified version of

'the FCR (as noted.in the drawing revision block) was incorporated into revision 3 of the Bechtel drawing, which was issued on October 4, 1984. As shown on the drawing, the detail is now applicable to both Units 1 and It appears that the penetration was reworked ~in accordance with the FCR, so that the as-built configuration is not in agreement with the design drawing. The Bechtel civil / structural site engineering organization indicates that FCR BC-01202 was incorrectly incorporated into Rev. 3 of the Bechtel drawing, and issued Drawing Change Notice (DCN) No. 3 on November 16, 1985 to correct the drawin FCR CC-03426.was issued on June 23, 1984 against Rev. 7 of Bechtel drawing 3M35-9S-3741 The FCR was issued to shift a piece of supplementary steel in plan to provide support for a hanger for Unit 1 only. The FCR was incorporated into Rev. 8 of the Bechtel drawing, but this detail is now applicable to both Units 1 and The drawing revision block does not indicate that the FCR was modified upon incorporation into the drawing. The Bechtel civil /

structural site engineering organization indicates that the decision was made to shift the steel for Unit 2 as well, at the time the FCR was incorporated into the drawin DCN No. 7 was issued on September 26, 1984 against Rev. 1 of Bechtel drawing 3C01-9-S-1600. The DCN was issued to provide support details for.RHR pumps A, B and C in Unit 1 containmen The DCN was modified upon incorporation into Rev. 2 of the Bechtel drawing, as noted on the drawing revision block, to be applicable to both Units 1 and FCR CC-04949 was issued on December 22, 1984 against Rev. 3 of Bechtel drawing 7G-22-9-S-2002. The FC9 revised support details for relay racks ERR 126 (nonsafety) in Units 1 and 2. The FCR was modified upon incorporation into Rev. 3 of the Bechtel drawing, as noted in the drawing revision block, and as detailed on the drawing. However, the location of the revised steel in plan was not clouded, and the 13/16 in. bolt holes for the support channel were not transferred onto the drawing. The Bechtel civil / structural site engineering organization has verified that the support was installed as detailed on the drawing, and issued DCN No. 18 on November 18, 1985 to correct the drafting erro VII-21

-

TABLE VII-4 - (Continu;d)

. REVIEW OF DESIGN CHANGE DOCUMENTS FOR INCORPORATION INTO DESIGN DOCUMENTS ITEM OBSERVATION 5 FCR BC-01279 was issued on July 24, 1984 against Rev. 1 of Bechtel_ drawing 7G22-9S-2010. The FCR adds a supplementary steel beam to provide support for exhaust fans 8V321(2)VFN013 and _4 (nonsafety) in the turbine generator building. The addition of the supplementary steel is required because of interference _ with a concrete block wall. FCR BC-01279 was superseded by FCR CC-04461, which restricted the identical support detail for installation in Unit 1 onl FCR-04461 was modified upon incorporation into Rev. 3 of the Bechtel drawing, as noted in the drawing revision block, for installation in Units 1 and 2. The Bechtel civil / structural site engineering organi-zation issued DCN No. 4 on November 18, 1985 to restrict the application of FCR CC-04461 to Unit 1 onl DCN No. 2.was issued on October 6, 1984 against Rev. 1 of Bechtel drawing 3C01-9-S-1603. The DCN.provided construction details for the carbon unit A and B fan supports in containment for Units 1 and 2. The DCN was correctly incorporated into Rev. 3 of the Bechtel drawing, except for.a minor drafting error involving failure to dimension a steel connection plat The Bechtel civil / structural site engineering organization issued DCN No. 3 on November 15, 1985 to correct the drawin FCN BS-1-0194 was issued on July 9, 1984 against Bechtel drawing CV-9010-GU0006, Rev. The FCN revised the bill of materials <

for a pipe support configuration to allow the installation of a rigid sway strut from bulk stock for-Unit 1 onl The FCN also specified the center-to-center dimensions for the Unit 1 strut However, the drawing did not properly specify the different ,

center-to-center (C-C) dimensions required ~for the strut The C-C dimensions for the Unit 2 struts were listed in the bill of materials (apparently past practice) while the C-C dimensions for the Unit 1 struts were dimensioned on the drawing. However, the drawing did not restrict the use of these strut C-C dimensions to the Unit 1 struts. The Bechtel pipe support group site i engineering organization issued DCN No.1 on November 18, 1985 to correct the drawin FCN BS-1-0235 was issued on August 5, 1984 against Rev. 2 of Bechtel drawing CC-9215-RR0005. The FCN was incorporated into 1 Rev. 3 of.the Bechtel drawing on March 12, 1985. The team !

reviewed the drawing, which details separate pipe supports for Units 1 and 2. The supporting steel for these supports appeared to require stiffeners, and the team then reviewed the pipe support calculation. Rev. 1 of calculation JC-CC-92-15-RR0005, dated September 30, 1985, does require beam stiffeners for both the pipe support supplementary steel and the support.ng framing VII-22

TABLE VII-4 - (Continued)

REVIEW OF DESIGN CHANGE DOCUMENTS FOR INCORPORATION INTO DESIGN DOCUMENTS ITEM OBSERVATION

. steel. Bechtel~ issued two separate configuration control packages on October 30, 1985 to add beam stiffeners to the pipe support steel, CCD-1-M-ST-0066-00 and 2-M-ST-0067-00; however, the beam ;

stiffeners to be added to the supplementary steel for the Unit 2 pipe support were not clouded on the pipe support drawing. The Bechtel pipe support group site engineering organization issued FCR XEJ-00371 on November 18, 1985 to correct the configuration control package for Unit VII-23

-- -. .- , .-. . , . . . - , - . - - - - . .. -- .- .. . -

TABLE VII-5 SOUTH TEXAS PROJECT AUDIT SAMPLE Audit-No. Audit Date Audit Subject EQA-123 12/07/84 Document Control / Instructions and Procedures, FCNs ESI-14-84 11/26/84 Evaluation of Design Control Operations BEC-6-84 05/24/84 Document Control - Field Control of Design Documents (Unscheduled Audit)

BEC-7-84 07/18/84 Evaluation of Quality Program for-Procurement Document Control BEC-8-84 08/14/84 Evaluation of Quality Program for QA Records BEC-10-84 09/28/84 Evaluation of Compliance to Quality Program Requirements for Design Control and Project Engineering-Design Interface Activities BEC-11-84 10/31/84 Evaluation of Quality Program for Evaluation of' Compliance to Quality Program Requirements for Preparation, Review, Approval and Control of Procedures C14-501 02/06/85 Ebasco Structural Steel Installation Activities G35-501 02/06/85 HL&P-RMS Site Records Retrieval G39-501 03/13/85 HL&P/Bechtel/Ebasco-Quality Records M24-501 04/18/85 Westinghouse - Site Activities S15-501 04/15/85 Bechtel Control of Westinghouse Design Disclosure Documents D08-501 04/23/85 Bechtel Design Control (Houston & Site)

G42-501 06/06/85 Bechtel/Ebasco Document Control M16-501 07/25/85 Ebasco Valve & Pipe Installation 008-502 10/22/85 Bechtel Design Control (Houston & Site)

S23-501 10/16/85 Bechtel Document Control of Ebasco and Westinghouse Documents VII-24

TABLE VII-6 REVIEW 0F CALCULATIONS STRUCTURAL SAMPLE ITEM .0BSERVATION 1- Drawing Change Notice (DCN) No. 5 issued on August 9, 1983 against Bechtel drawing No. 3F01-9-S-3005, 'added support details for Fuel Handling Building heating coils 8V121VHX001 and -002 at two plan elevation Bechtel had performed a calculation for the support steel for this non-safety equipment but the calculation had not been checked or signed by the group leader at the time of the inspection. Bechtel did not assign a number to this calculation, and does not plan to formalize this calculation.

2 Bechtel' drawing No. 3M01-9-S-4043, issued on November 5,1984, 1 revised the structural steel floor plan in the Mechanical and Electrical Auxiliary Building between column lines 30 and 32, and column lines M8 and H, at plan elevation 69 ft.-6 in. Field Change Notice (FCN) 1-C-0265, issued on March 6, 1985, provides

.the fabrication details for the structural steel adjacent to a pair of HVAC openings located in the southeast corner of the floor plan. The CAT team requested the calculations for the structural steel detailed on the FCN. Bechtel indicates that engineering judgment was used to size the installed steel. However, this engineering judgment was not documented. The Bechtel civil /

structural site organization has verbally indicated that calcula-tions could not be retrieved for any of the four above-referenced bays of structural steel in the Mechanical and Electrical Auxiliary Buildin DCN No. 5, issued on October 24, 1985 against Bechtel drawing No. 3M01-9-S-4069 Rev. 4, added a transverse stiffener beam between two existing parallel beams which support pipe hanger The beam was added to increase the torsional stiffness of the existing beams. The added steel is located in the Mechanical and Electrical Auxiliary Building. The team requested the structural calculation for the added steel beam. Bechtel provided a recently completed calculation which verified the adequacy of the added beam (Rev. 1 to Bechtel calculation N CC-6043, dated November 13, 1985). Each of the existing steel beams was also checked in this calculation. The stress in one of the beams is 86 percent of. allowable load capacity. The stress in the other beam is 109 percent of allowable load capacity. These beams were subjected to generic dead and live distributed loads, a concentrated live load, and peak vertical and horizontal seismic spectra (i.e., the loads that would normally have been used to size this steel initially). It appears, however, that this is the first formal check of this stee VII-25

TABLE Vl"-7A ELECTRICAL-AND INSTRUMENTATION CONSTRUCTION HARDWARE SAMPLE Change Document FCR DE-00274 FCR CE-04476 FCR CE-04475*

FCR CE-05252 FCR CE-05302 FCR BE-00536 FCR CE-05294 FCR CE-04881 DCN No. 8 (Dwg. 3D019-S-5002)

FCR CC-D5635 FCR XDE-00055 FCR CE-04284 FCR BE-00674 FCR BM-00225 FCN TGXM-10585, A, B, C*

(*) Refer to Section II, Electrical and Instrumentation Construction, for a-discussion of the deficiencies noted with the implementation of these design change document VII-26

TABLE VII-7B MECHANICAL CONSTRUCTION. HARDWARE SAMPLE Change Document A. Piping FCR DP-451 FCR DP-541 FCR DP-57-1 FCR DP-503 FCR DP-690 FCR DP-748'

FCR DP-662 FCR DP-669 FCN IP-1125 FCN IP-1074 FCN IP-1069

'FCN IP-1067 '

FCR DP-269W FCR DP-614 FCR DP-916-FCR DP-14W DCN Nos. 14 & 15 (Dwg. 5M369PCC207, Sh. 10, R.1)

FCN IP-1384 FCR DP-939W

.FCR DP-918

.FCR DP-772 FCR DP-751 FCR DP-739 FCR DP-718 FCN IP-1081 FCN IP-1106 FCN IP-0836

<

B. Pipe Supports FCN IP-0981 FCR DJ-00248 FCR XEJ-00185 FCN J-0919 FCR DJ-00368 FCR DJ-00306 FCR DJ-00374 FCR DJ-00648 FCR DJ-00440 FCN J-0967 FCN J-0968 NCR BS-00212 VII-27

TABLE VII-7B - (Continued)

MECHANICAL CONSTRUCTION HARDWARE SAMPLE Change Document Concrete Expansion _

FCR CM-02181W-Anchors and Base Plates NCR CM-00587 NCR CS-00802 NCR CS-03103 NCR CS-01014 FCR DJ-00787

'

FCR DJ-00994 FCR DJ-00894 FCR EJ-00289 1

'

-FCR J-0983

DCN No.1 (Dwg. CC9317-HL5006)

FCR DJ-00763 HVAC FCR BH-00827 FCR CH-01546 FCR BH-00559 FCR CH-00845 FCR CH-01800 FCR DL-00152W 3 FCR CH-02181W FCR EAB-314 FCR BH-01844 FCR BH-01142

.

\

VII-28

, . ..

. . - . . - . . - . - . . , , - - - . ,. .. .

. .. . . - _

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

..

TABLE VII-7C CIVIL / STRUCTURAL CONSTRUCTION HARDWARE SAMPLE Change Document FCR EC-00318 FCN 2C-0450-FCR EC-00321 FCR EC-00098 FCR EC-00318 FCR CM-00194 FCR CC-02180 Dwg. No. 3C01-9-S-1633, Rev. 10

,

'

,

t i

i f

f VII-29 i _ _ _ _ _ . _ . ._, _ . . . - . _

__ _ - - -

- - _ _ - . .

,

VIII. CORRECTIVE ACTION SYSTEMS A. Objective The objective of this portion of the NRC CAT inspection was to verify through selected samples, whether measures were established and implemented to assure that nonconformances and other conditions adverse to quality were promptly identified and correcte r Discussion An examination was made of the licensee's program for identification i

and control of nonconformances and corrective actions, including review of documents and inspection of some material / equipment for verification of actual corrective actions in the plant. Items such as the following were reviewed:

• Quality assurance programs Procedures and organizational interfaces Trend analyses

• Audits and surveillance reports

'* Nonconformance reports r Deviation reports ( * Inspection reports ( * Corrective action reports

• Control of actual material / equipment corrections in the plant

• Control of open nonconformances at turnover for testing or operation Table VIII-1, " Corrective Action Samples," contains a list of samples that were randomly selecte The following manuals and procedures of on-site organizations were found in place, and applicable portions pertaining to corrective action provide the background infonnation and acceptance criteria for this inspectio Houston Lighting and Power Company (HL&P)

• Quality Assurance Program Description for the Design and Construction Phases of the South Texas Project, Rev. 11 Project Quality Assurance Plan, Rev. 7 South Texas Project Quality- Assurance Procedures, Rev. 46 Standard Quality Assurance Procedures:

SQAP-01 General Control of Standard QA Procedures, Re SQAP-02 Deficiency Reporting, Re SQAP-03 Project Audits, Re SQAP-04 Project Surveillances, Rev. 1 PSQP-16.3 Trend Analysis, Rev. 3 SSP-8 Nonconformance Reporting, Res. 0 VIII-1

- _ _ _ _ _ _ _ _ _ _

OPGP03-ZM-0002 Preventive Maintenance Program, Rev. O Bechtel Power Corporation (Bechtel)

Project Quality Program Manual, South Texas Project, Rev. 11 WPF/QCI.-4.0 Receiving Inspection, Rev. 11

• WPP/QCI-5.0 Nonconforming Materials,. Parts and Components, Rev. 14 WPP/QCI-28.0 Maintenance of Materials and Equipment, Rev.11 SQAP-04 Project Surveillances, Rev. 1 Ebasco Services Incorporated (Ebasco)

_ETR-1001 Nuclear Quality Assurance Program Manual, Rev. 11 QAI-11 Corrective Action and Stop Work Authority, Rev. 7 QCP-10.9 General Inspection (G series), Rev. 2

• QCP-10.30 Inspection of Installation and Fabrication of Electrical Cable Tray Hangers, Conduit Supports and Auxiliary Steel, Re * QCP-10.11 Mechanical Equipment Installation Inspection, Rev. 5 Westinghouse Construction Services (Westinghouse)

• Quality Assurance Program Manual (QAPM) for ASME Code Section III, Division I QAPM Addenda for South Texas' Project (yellow pages)

• QAPM Addenda, Section 15.0 Nonconformances, Rev. 9 QAPM Addenda, Section 16.0 Corrective Action, Rev. 7

• STP Project Quality Plan, Rev. 4 Pittsburgh DesMoines St' eel Company (PDM)

Corporate Quality Assurance Manual (CQAM) ASME Section III, 1981 Edition, Rev. 8 CQAM Appendix 202 (for STP), Section 12, Nonconformances and Corrective Action Richmond Engineering Company (RECO)

Quality Assurance Manual, South Texas Project, Rev. 3 Intermach Company (Intermach)

Quality Assurance Manual (The Bahnson Co.), Rev. 9 VIII-2

.

-

-.

m .

J

• QFP-15.001 Nonconfonning Items, Rev. 4

• QFP-16.001 Corrective Action, Re * QFP-8.001 Identification and Control of Materials, Parts and

.

'

Components, Rev. 3

• QFP-9.001 Control of Welding Processes, Rev. 3

- * QCI-013 Control of Nonconforming Items, Rev. 2 Prescon Corp. (Prescon)

• Quality Assurance Program, Rev. 10 Champion, Inc. (Champion)

• Quality Assurance Manual, Rev. 26 Pittsburgh' Testing Laboratory-(PTL)

• Quality Assurance Manual, Rev. 8 Corrective Action Measures Inspection Scope A review was performed of applicable portions of the Quality Assurance (QA) program and procedure In addition to QA manuals and procedures, a total of 439 samples of corrective action docu-ments were reviewed. . Also,'16. samples-of closed nonconformances involving material / equipment were inspected for verification of corrective actions in the plan In' addition, 58 samples of open nonconfonnances were selected for verification of " HOLD" statu Inspection Findings In general, it was found that satisfactory procedures were in place for corrective action systems to identify and control the correction of conditions adverse to quality at the site. Except for concerns discussed below, the corrective action systems and implementing measures were found to be acceptable. The 16 material / equipment samples requiring rework in the plant were inspected, and corrective action control was verifie (1)' Fastener Materials Numerous problems with fastener material discrepancies on large vendor-supplied ASME pump / motor assemblies and other vendor equipment were found by the NRC CAT inspectors for which effective corrective actions were not previously eviden See Section VI.B for details. These problems indicate a lack of attention by vendors to ensure that fasteners of required materials are specified and provided with delivered items, a lack of effective quality control at vendors'

VIII-3

'

.

~

plants, and also a lack of vendor surveillance by the licensee wi_th ' attention to' verification of proper fasteners prior to shipmen '

(2) Preventive Maitenance (PM)

Review of the PM program revealed that numerous problems have been encountered, including overlubrication and contamination due to commingling of lubricants.. Seven fan motors, after

- turnover to Startup, .were _later found to have been overlubricate Review of PM history of four Auxiliary Feedwater Pumps (three motor: driven and one turbine driven) revealed repeated corrosion problems. One unit seized and could not be rotated. Rotating . elements of the four_ units had to be returned to the ' vendor for repair .The NRC Resident Inspection Office has issued inspection reports (85-08 and 85 11) on PM deficiencies. Also, Ebasco issued a Management Corrective Action Report .MCAR-13 dated February 23, 1985 which contains a list of 106 deficiencies and resulted in a major review and reorgnization of the PM progra Of parti _cular concern is the current practice of the' licensee _

accepting turnover packages and preparing operational maintenance programs assuming that the past PM history is good without assessing potential for damage to the equipment due to past PM deficiencies. The potential long term effects of' the lack of proper maintenance-has not been addressed and documented, and it does not appear that measures-(reference:

OPGP03-ZM-0002 Preventive Maintenance Program, Rev. O, dated 5-15-85) were in place to. provide for damage assessment and.

'

evaluatio (3) Nondestructive Examination (NDE)/ Radiographic Testing (RT)

Audits; Records Retrieval Review of'the total .of 21 prior audits of welding /NDE revealed only two audits that addressed RT records packages and retrievability (audits M11-301 and G35-502). These two audits included three weld joints for one audit and six weld joints for the other. The total of 9 weld joints (of approximately 25,000 field weld joints) is a very small sample to have been audited. NRC CAT examination of the radiographs for'two of the three welds for audit M11-301 found them to have deficiencies,

' indicating that the audits.were limited in scope and depth (see Section IV.B 'for details).

None of the 21 prior audits covered vendor NDE/RT record Requests for information to identify vendors that were required to supply radf ographs were not'readily answere Some radiographs from vendors involving plant equipment were not made available to the NRC CAT inspectors, and in some VIII-4

cases could not be located. A method for identifying vendors, equipment and related radiographs was not available at the start of the CAT inspection (see Section IV.B for details).

The required records retrieval for RT film was not evident during this inspection, and raises questions regarding the ability of the licensee to verify the required product quality, if records are not readily availabl '(4),, Significant Deficient Corrective Actions for Certain Electrical Items: Motor Operated Valves (MOVs) and Motor Control Centers MCC)

Corrective action deficiencies related to unauthorized electrical wiring of MOVs furnished by Westinghouse were noted by the NRC CAT inspectors (see Section II.8). Questionable QA and corrective action activities involving design change control, field modification and inspection were indicate It was noted that no audits or surveillances of Westinghouse activities related to MOVs had been conducted. However, one HL&P audit report, S26-501 dated September 24, 1985 addr(ssed field wiring changes by Westinghouse on other electrical equip-ment inspected and accepted at the site without prior written authorization for the changes. The response by Westinghouse noted a procedure change for accelerated Field Change Notice (FCN) work to require written authorization prior to the wor Also, a project team audit S15-501 dated April 15, 1985 referenced a prior HL&P audit M24-501 of Westinghouse which addressed deficiencies in the electrical area. It appears that the generic aspects of these audit results were not applied by Westinghouse to the MOV~ wor Also, corrective action deficiencies related to faulty bus extensions of circuit breakers in MCCs procured by Bechtel were noted by the NRC CAT inspectors (see Section II.B).

(5) Open Nonconformances " HOLD" Status Control Open Nonconformance Reports (NCRs) and related equipment requiring " HOLD" tags for 58 items were reviewed for verificatio " HOLD" tags for 13 items (22%) were missing or improperly controlle Since " HOLD" tags are required to be used as a means of controlling quality, attention and action are required to assure proper application and maintenance of "H0LD" tags on nonconforming material and equipment. As a result of this NRC CAT finding, Bechtel issued General Surveillance Report SB 727 to document incorrect " HOLD" tag control, Conclusions The licensee's corrective action program was found to be generally acceptable, except for the following concerns:

VIII-5

r-(1) Failure to assure that fasteners of required materials were furnished with vendor supplied equipmen (2) Failure for Operations to assess and evaluate damage to equipment due to past PM deficiencies and incorporate such considerations into operational maintenance program (3) Failure to conduct a reasonable quantity of audits of actual radiographs of both field welds and vendor supplied weld Also, failure'to assure that vendors required to supply radiographs were readily identified and that the location of radiographs / records were known and readily retrievable as require (4) Failure to identify the need for effective corrective action activities for certain electrical items: MOVs and MCC (5) Failure to properly apply and control " HOLD" tags on nonconforming material and equipmen (6) There appears to be a need for more ~ attention to generic and lessons-learned aspects of the corrective action program to help reduce deficiencies and avoid recurrenc VIII-6

C L

r _ , , - -

.~ l r

,

p .

L~

j;;

,

-TABLE VIII-1 p CORRECTIVE' ACTION SAMPLES

[

>

JItems/ Reports Quantity Examined L HLP BEC EBA' WES PDM -REC INT PTL- TOTAL L . Trend 3* *- * ~3 - - -

- . Audit' 41* * * 6 3 '-- -1 -

Nonconformance 17 61 69 6 5 5 .12 5 180 l- ~

Deviation -- - -

10 8 -

.15 -

33.

Inspe'ct' ion

-

-

5 18 - - - 4 -

l- . Surveilla'nce -14 19 12 - - - - -

i

"

Corrective Action 9 18 12 - - - - -

L

!

Deficiency Eva .20 i :Mgt. Corrective - -

4 - - - - -

l

,

. Action-Inspection 9 - - - - - - ~ -: 9 Efficiency-l L

/Stop Work ~ 3 -

1 - - - .

-

'4 Turnover. Packages 20 - - - - - --

. 20 p-T

~

TOTA'l TE6 TIT IT6 Y5 T6 72 - ! . TJB

'

L_ HLP = Houston' Lighting and Power Company BEC = Bechtel Power-Corporation

=

',

. EBA = Ebasco Services Incorporated L . WES =. Westinghouse. Construction Services D PDM = Pittsburgh DesMoines Steel. Company REC = Richmond Engineering Company

.

INT.= Intermach Company PTL = Pittsburgh.. Testing Laboratories

-

v

• Joint (HLP,. BEC, and EBA) trend and audit program samples listed under' HLP, ,

' l l

l l

l VIII-7-

L___'

_

ATTACHMENT A A. PERSONS CONTACTED The following list identifies 1 censee representatives and NRC personne1'

present at the exit meeting, and licensee discipline coordinators and key individuals-contacted during the inspection for each are . Exit Meeting Houston Lighting and Power Company F. L. Alkov G. Goldberg T. H. McGriff J. Bevins S. Head R. C. Munter P. F. Boyle R. Hernandez A. G. Peterson D. P. Bradley S. R. Hubbard G. B. Rogers R. J. Daly M. F. Hutcheson M. T. Sweigart S. Dew T. J. Jordan W. Trujille F. Dotson D. R. Keating J. Westermeier J. E. Geiger W. H. Kinsey, J W. R. Whitley M. R. Wisenburg Bechtel Energy Corporation R. D. Bryan L. W. Hurst -R. L. Rogers J. L. Hurley D. R. Quattrochiocchi R. Wilkerson Ebasco Services, Incorporated A. M. Cutrona W. Taylor R. W. Zaist R. A. Harrington Westinghouse Ele-tric Corporation D. M. Bokesch C. W. Rowland F. J. Twogood H. L. Hogarth S. R. Spiegelman R. J. Von Osinski NRC and Consultants S.' Baron D. Garrison T. McLellan W. Sperko D. Carpenter G. Georgiev 0. Mallon S. Stein L. Constable R. Heishman E. Martindale R. Taylor R. Compton C. Johnson J. Nemoto R. Vollmer A. DuBouchet R. Kadambi M. Peranich D. Ford J. McCormack H. Phillips AA-1

. .-

'~

. ~ .

'

r.-

, Licensee Coordinators and Contacts'

Area' Contact

= Team-Leader- R. Hernandez

-

W. Trujillo

Electrical and Instrumentation D. Bradley-D.-Richter J. Bagley Mechanical M. Hutchesa S.' Hubbard J. Bagley C. Brewer A. Benyo

~

Welding and NDE S. Hubbard R. Abel-R.. Lewis Civil and Structural 'T. McGriff J.-Stevens

.

Material. Traceability F. Alkov J. Senecal

~~R. Fish Corrective Action Systems E..Luder-J. Hansen Design Change. Controls - K. McNeal

.In addition to the above personnel, numerous other inspectors, engineers-and supervisors were also contacte ~ DOCUMENTS REVIEWE The types of documents listed below were-reviewed by the NRC CAT members-to the extent necessary to satisfy ~the inspection objectives stated i 'Section I of this report. There are' additional references within the body of.the report to' specific procedures, instructions, specifications and drawing . F.inal Safety Analysis Report and. Safety Evaluation Report

. lQualityassurancemanual

' ' Quality assurance procedures and instructions ' Quality control procedures and instructions Administrative procedures General. electrical installation precedures and specifications AA-2

.-

_ . .

.

,

_ General instrumentation . installation procedures and specification .r : General piping and pipe support installation procedures and specifications

~~ General mechanical equipment . installation procedures and specifications-

'

c ,

!10. -General concrete specifications  !

11. As-built. drawings 12.. Welding and NDE procedures

.1 Personne1~ qualification records 1 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 se AA-3

, <

,

. . .

~ ATTACHMENT B GLOSSARY OF ABBREVIATION _ .

A/E - Architect-engineer

'AIS American Institute of Steel Construction ANSI '- American National Standards Institute

'

ASME - American Society of Mechanical Engineers

' ASTM .American Society for Testing and Materials AWG - American Wire Gage AWS --American Welding Society

'ATWS' - Anticipated transient without scram BBC- -TBlount Brothers Company BEC_ ' -~Bechtel Engineering Corporation-BR- - Brown & Root, In , . CAR- - Corrective Action Report CAT - Construction _ Appraisal. Team (NRC)

'

CB& Chicago Bridge and Iron Company CCP - Configuration Control Package C of C - Certificate of Conformance CEA - Concrete expansion anchor

, CMTR- ~- Certified material test report CPS -Construction Process Sheet CSP - Construction Site Procedure

.DCN Drawing Change Notice DEF - Deficiency Evaluation Form DER - Deficiency Evaluation Report

-

DR ' - Deviation Report ECN : Engineering Change Notice

- Essential Cooling Water

~

'

ECW

, EDP- - Engineering Department Procedure

'

.ERSA - Engineering Request for Site Action

'FCN '- Field Change. Notice FCR - Field Change Request FDCC Field Document' Control Center-FRLL - Field Revision List

. FSAR - Final Safety Analysis Report HEco - Hatfield Electric Company I

HL&P - Houston Lighting and Power Company

'

Hunter- - Hunter Corporation

.HVAC - Heating, ventilating and air conditioning

IE - Office of Inspection and Enforcement (MC)

'IEEE

-

- Institute of Electrical and Electronic Engineers L IPCEA - Insulated Power Cable Engineers Association

'

LP -- - Liquid penetrant inspection LOCA - Loss-of-coolant accident MC Motor Control Center MCM - Thousand circular mils MIC - Midway Industrial Compan MOV - Motor operated valve

!- NCR - Nonconformance Report j3 NDE - Nondestructive examination AB-1

--

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

,

NISCo - Nuclear Installation Service Company

' Nuclear Power Service, In ~

NPS'

NRR - Office'of Nuclear Reactor Regulation (NRC)

NRC .U.S. Nuclear Regulatory Commission-

'

.NSS Nuclear. steam system supplier PAP - Powers-Azco-Pope

. PDM - Pittsburgh Des Moines Corporation PED Project Engineering Directive-PSAR . Preliminary Safety Evaluation Report

PSI - Preservice inspection PTL' - Pittsburgh Testing Laboratories'

QA - Quality assurance QAI - Quality Assurance Instruction QAM' - Quality Assurance Manua QC - Quality Control-QCP - Quality-Control Procedure

~

QR - Quality Requirement RG' - Regulatory Guide (NRC)

RHR - Residual Heat Removal System RSM - Reliable Sheet Metal Works, In RTD -- - Resistance Temperature Detector

.SAR - Safety Analysis Report SDR -. Standard Deficiency Report SE Site Engineering Organization SIP - Site Implementation Procedure SSP - Standard Site. Procedure STP - South Texas Project SWI - Site Work Instruction SWR- - Startup Work Request UT - Ultrasonic inspection V - Volt VT. - - Visual inspection

- Westinghouse Electric Corporation

'

W.

i AB-2

__ _

._. _

-,

_7 NRC Form 8-C (4-79)

NRCM 0240 o

COVER SHEET FOR CORRESPONDENCE Use this Cover Sheet to Protect Originals of Multi-Page Correspondenc >

d L

q

-

.

= r re ~,, ~;

-

.

_

, _

_ , ,

,

,

y;, ' "

,

'

_. ..

~

'.'.: ' _

,

>

r; -

.

,.

,

.j - ,

t

'

' w' f ~ .~j m ,

= ,

4 *

3,.

9 = '-

__ t7e .g. ; j t .

A

_*. g i i' I' _

• ' ,

, :;s .

> > a s

, ~ > ,

-

~

? ..l

-

s

,

9 .

,

'

[. ,'

.

• . f? ~ #' "

({p' . )y f0, igf ..3p ,

( ,. I , . ,. [;( r

. ,. .

-

t ..

'

&. [f

'

s

- -

w

.c -- p, . r,a ,

)

~ ..

, . -

.s

.s . .

..

.2

. .> o

'

W 3---

,

' ~ l?!d, _ t, _ : e

it ,. . .A,q . , *.. . .

~;

.

_

,

-

c py

.,

g .

p j ;p+,y' p# :

,

-- '

,

' *. .. A

'

l a $* . -f W} .y' -

,- 4  ;

_

,o

..- /.$.

'/i 4 h^

d

.  ;

i

%

k

.

t-I~

/

$

i w

- .

g.

1. '

-

+fj; 4 ,

F

..

,-

. .

_

I j- s t.

t.

!

,

f

4

, . .,.

r I

hJ _ v6 m-

.g

,o .-____-.___;.,____-_..-_-_--