IR 05000443/1982003

IE Insp Repts 50-443/82-03 & 50-444/82-03 on 820323-0503. Noncompliance Noted:Failure to Establish Insp Program for Installed Cable Tray & Failure of QC Pipe & Electrical Support Insp to Identify Nonconforming Conditions

ML20054F800
Person / Time
Site:	Seabrook
Issue date:	05/26/1982
From:	Cerne A, Gray E, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20054F791	List: IR 05000443/1982003 ML20054F790 ML20054F792
References
50-443-82-03, 50-443-82-3, 50-444-82-03, 50-444-82-3, NUDOCS 8206170340
Download: ML20054F800 (16)

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U.S. NUCLEAR REGULATORY COMMISSION Region I 50-443/82-03 Report N /82-03 50-443 Docket N CPPR-135 License No. CPPR-136 Priority --

Category A Licensee: Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105 Facility Name: Seabrook Station, Units 1 and 2 Inspection at: Seabrook, New Hampshire Inpsection conducted: March 23-May 3,1982 Inspectors: C . 'LO N A. C. Cerne, Sr. Resident Inspector date signed y [f/7l6 L E. H. Gray, React spector date signed

/ d R;/J. Paolino, Reactor Inspector f//3)$ L date/ sigrfed p /

/ C A. A. Varela, Reactor Inspector date signed'

Approved by: I Ok tv -

R. M. Gallo,' Chief, Projects Section 1A, 26 8 date signed Division of Resident and Project Inspection Inspection Summary; Unit 1 Inspection on March 23-May 3,1982 (Report No. 50-443/82-03)

Areas Inspected: Routine inspection by the resident inspector and regional based inspectors of procedures, records, and work activities relative to electrical component procurement, installation and inspection; reactor coolant pipe welding; rebar cadwelding; corrective action on ground water leakage; support erection to include the kwik-bolt installation program, and follow-up of a 50.55(e)/Part 21 item. The inspectors also reviewed licensee action on previously identified items and performed plant inspection-tours. The inspection involved 139 inspector-hours, including seven off-shift hours, by four NRC inspectors.

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Results: Of the six areas inspected, one violation was identified in each of the following areas: Failure to establish an inspection program for installed cable tray (paragraph 8),

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and failure of QC pipe and electrical support inspections to identify nonconforming conditions (paragraph 13a).

8206170340 820526 DR ADCCK 05000

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Unit 2 Inspection on March 23-May 3.1982'(Report'No. 50-444/82-03)

Areas Inspected: Routine inspection by the resloent inspector and regional based inspectors of procedures, records and work activities relative to electrical component procurement, installation, and inspection _; rebar cadwelding; corrective action on ground water leakage; support erection to incicde the kwik-bolt installation program, and follow-up of a 50.55(e)/Part 21 item. The inspectors also performed plant inspection-tours. The inspection involved 49 inspector-hours, including three off-shift hours by four NRC inspector Results: Of the five areas inspected, one violation was identified in one area -

Failure to establish an inspection program for installed cable tray (paragraph 8).

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DETAILS Persons Contacted during 82-03 Inroection Yankee Atomic Electric Company (YAEC)

F. W. Bean, Lead Electrical QA Engineer F. X. Bellini, Site Geologist D, L. Covill, Lead Civil QA Engineer R. E. Guillette, QA Engineer (Framingham)

J. H. Herrin, Site Manager (PSNH)

J.J. Lance,NDEEngineer(Framingham)

G. F. Mcdonald, Jr., QA Manager (Framingham)

J. F. Nay, Jr., Lead Mechanical QA Engineer S. B. Sadosky, Lead Start-up/ Test QA Engineer J. W. Singleton, Field QA Manager R. Tucker, Engineer (Framingham)

United Engineers and Constructors (UE&C)

R. G. Blair, Civil Superintendent R. H. Bryans, Site Engineering Manager A. G. Bryce, Field Civil Supervisor S. A. Buta, Area Engineer J. A. Grusetskie, Engineering Manager Assistant C. D. Hanson, QA Supervisor

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F. N. Jathavedam, Lead Raceway Support Engineer

• Knox, Electrical Engineer (Philadelphia)

D. C. Lambert, Field Superintendent of QA D. E. McGarrigan, Project QA Manager (Philadelphia)

• S. Rubenstein, Senior QA Engineer (Philadelphia)

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Fischbach-Boulos-Manzi (FBM)

W. L. Columbia. Construction Manager F. Kollin, Project Manager Johnson Controls, Inc. (JCI)

A. O. Kennedy, QA Manager H. E. MacNeil, Support Engineer R. G. Walter, Project Engineer i

Pullman-Higgins (Pullman) i R. G. Davis, Field QA Manager R. P. Donald, QA Supervisor D. B. Hunt, QA Records Supervisor Royal Insurance J. C. Anzivino, Authorized Nuclear ~ inspector i

• indicates telephone comunication

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b. Persons Attending Management Meeting on April 8,1982 (See paragraph 15b)

PSNH Da dd N. Merrill, Executive Dale E. Flemming, QA Supervisor J. A. Philbrick, Project Engineer YAEC Wendell Johnson, Vice-President John DeVincentis, Project Manager Arthur M. Shepard, Director of QA Gerald F. Mcdonald, QA Manager H. E. Wingate, Sr., Project Engineer J. W. Singleton, Field QA Manager UE&C ICT. Kreider, Manager-Power En A. M. Ebner, Project Manager D. H. Rhoads, Project Eng Manager D. E. McGarrigan, Manager-Project QA R. H. Bryans, Site Eng. Manager USNRC E. J. Brunner, Branch Chief, Region I R. M. Gallo, Chief Projects Section 1A, Region I L. L. Wheeler, Project Manager, Div. of Licensing, NRR D. D. Chamberlain, Reactor Engineer (Systems), Region IV

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A. C. Cerne, Sr. Resident Inspector, Region I l S. K. Chaudhary, Reactor Engineering Insp., Region I l

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. . Plant Inspection-Tours (Units 1 and 2)

The inspectors observed work activities in-progress, completed work and plant status in several areas of the plant during general inspections of the plan The inspectors examined work for any obvious defects or noncompliance with regulatory requirements or license conditions. Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservation. The inspectors interviewed craft personnel, supervision, and quality inspection personnel as such personnel were available in the work area Specifically, an inspector examined the condition of stud welds on the Unit 2 personnel air lock (PAL) prior to its erection into position in the containment liner. He noted and questioned certain studs which appeared to lack 360'

flash and other studs with head bursts. Further inspection by PDM and UE&C QA personnel revealed that while the head bursts were within acceptance criteria, five (out of 144) studs were rejected for incomplete wel A review of the PDM QA program as well as UE&C Vendor Surveillance Reports indicated that a similar problem had been identified by UE&C vendor inspectors on the Unit 1 PAL and corrective action had been taken. Other documentation (eg: PeriniContractorInterfaceReport110)revealedextensiveinspectionof the Unit 1 PAL studs prior to concrete embedment. The questionable Unit 2 studs were documented on a PDM Engineering Corrective Action Request (ECAR)

for further resolution. The inspector had no further questions on this issue since the inspection history indicated acceptability of the Unit 1 PAL and Unit 2 corrective action will be forthcoming upon disposition of the ECA Inspectors also reviewed Pullman Joint Torque Records for the bolted flange connections of service water piping and a Pullman Field Instruction for the removal of steam generator (SG) manway covers in conjunction with Westinghouse maintenance procedures. The need for more rigorous control of hold point implementation and approval of contractor field instructions was discussed with licensee personnel. While no specific safety concerns were identified,

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the licensee agreed to follow-up clarification of hold point usage within the sequence of bolting operations, control of the SG manway cover reassembly procedures, and certification of the lubricant recommended by Westinghouse for manway cover boltin Inspector-tours of the pipe fabrication shop, welder qualification and training areas, and turbine building were conducted. A record review of

UE&C Corrective Action Requests and Perini Deficiency Reports for the handling of concrete honeycomb problems in certain turbine building columns revealed adequate coverage, resolution, and documentation of specific repair items, even in nonsafety-related area An inspector reviewed the authorization (RFI 73/2283A) for substitution of bolts for studs in flanged piping connections in the cooling tower. Material certification, NDE, code applicability and thread protrusion into the connection were all verified as acceptable with regard to original design i -- - . _ _ _

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. . 6 considerations. Reactor pressure vessel support steel members (ERS-1 and 2), to be embedded in the Unit 2 pedestal were examined for weld quality and general confonnance to specification (18-1) and drawing (F101415 and FP12553) requirements. QA inspection coverage of these items was verifie With regard to all independent inspection items discussed above, no items of noncompliance were identifie . Licensee Action on Previously Identified Items (Closed) Infractions (80-11-01, 80-11-02, and 80-12-03) and Immediate Action Letter (IAL 80-55): Pullman pipe weld repair problems and stop work order. The inspector verified the continued implementation of corrective actions taken for release of the licensee stop-work order on weld repairs on February 6,1981. Specific measures documented in the licensee response of January 8,1981 to IAL 80-55 were checked against current contractor procedures, training activities, QC inspection coverage and QA audit Pullman welding repair procedure, JS-IX-14, was revised extensively to develop a dual repair process, separately covering the excavation and the repair welding. The inspector spot-checked weld repairs in process and documentation thereof and verified acceptable implementation of-the new procedur Specifically the inspector observed field operations and reviewed the complete weld packages for the following two multi-cycle repair processes:

-- ISO RH-155-02, field welds F0203 & F0205

-- ISO SI-204-02, field weld F0202 Acceptable welding procedures, NDE, inspection and documentation were noted and overall repair welding conformed to corrective action connitment These items are close (0 pen)10CFR50.55(e)/Part21 Reports: Raceway support bolted strut fitting design / testing discrepancies. (References: UE&C Part 21 Report, November 13, 1981 and PSNH 50.55(e) Interim Reports, August 25 and December 15,1981).

The inspector reviewed licensee and contractor actions to date to identify and control in the field all questionable hardware and suspect installed configurations. He noted that while the acceptable Unistrut parts had been procured in bulk for future installations, evidence of some questionable Powerstrut and Superstrut parts still remained in the field. Upon dis-cussion with QA and FBM personnel, a field inspection and recall of all these presently unauthorized parts was initiated- .

The inspector also questioned whether interchangeability of parts from the different manufacturers had been considered since previously installed con-figurations may consist of any combination of bolts, spring nuts, and fitting The testing program, however, had apparently only considered nut / bolt com-binations from the same vendor (eg: Unistrut with Unistrut, etc.). All prior questionable configurations have been identified and await engineering resolution of this problem. The inspector indicated to the licensee that part interchangeability was an additional item that must be considered in the final disposition and direction of corrective actio ' Electrical cable / terminations--Procedure & Record Review The inspector reviewed pertinent work and quality records for the installation and inspection of electrical components and systems. The following FBM procedures were examined for work and record conformance and evaluated for adequate program coverag Quality Assurance Procedures (QAP)-101SB1, Personnel Qualification and Certification - revision 3, dated May 5,1981

-- QAP-103SB1, Processing and Control of nonconformances - revision 3, dated June 29,1981

-- QAP-104SB1, Corrective Action - revision 1, dated February 6,1979

-- QAP-105SB1, Stop Work Order - revision 1, dated February 6,1979

-- QAP-106SB1, Auditing - revision 1, dated February 6,1979

-- QAP-201SB1, Control Filing of Maintenance Records - revision 1, dated April 17,1979

-- QAP-202SB1, Use of Inspection Tags - revision 1, dated February 6,1979

-- QAP-203SB1, Document Control - revision 1, dated February 6,1979

-- QAP-204SB1, Preparation of Quality Control Procedures and Instructions -

revision 2, dated April 7,1980

-- QAP-301SB1, Receiving Inspection, General revision 1, dated June 20,1979

-- QAP-302SB1, Conditional Release of Equipment and Material - revision 2, dated January 7,1980

-- QAP-303SB1, Material / Equipment Handling and Storage - revision 1, dated July 12,1979

-- QAP-401SB1, Control of Measuring / Test Equipment - revision 1, dated February 1,1979

-- QAP-403SB1, Housekeeping - revision 0, dated November 22,1978

-- Quality Control Procedures (QCP)-501, Inspection of Embedded Conduit Installation - revision 3, dated March 5,1979

-- QCP-502, Inspection of Exposed Conduit, Terminal and Pull Boxes / Support Installation - revision 2, dated July 2,1981

-- QCP-503, Inspection of Cable Tray and Support Installation - revision 2, dated July 2,1981

-- QCP-504, Inspection of Electrical Cable Installation - revision 2,

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dated October 12,1979

-- General Electrical Installation, Specification No. 9763-006-48-2 revision 6, dated September 10,1981 No items of noncompliance were identifie . Receiving Inspection

! The inspector reviewed pertinent material qualification documents for cable cray hardware identified in purchase order no. 109-1. The inspector was unable to determine acceptance criteria for the hardware due to confusing instructions in letters and procurement specification as follows:

-- Specification no. 9763-4224, item B-11 requires shop tests and inspection reports plus the material test report (MTR) and/or certification.

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-- FBM requisition No.45858 dated December 23,1981 indicates the MTR is not require UE&C letter of January 20,1981(&SB0241763) states UE&C will accept only those bolts having MIL certification with an identifying mar '

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-- Speed letter from QAE to Superintendent QA/QC dated January 29,1981 J states cable tray bolts will require an MTR with each shipment and that'~ '

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the blanket certificate of confonnance will no longer apply to cable

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tray bolt i'

-- FBM requisition nos.45858, 42833, 42843, 44146 and 36553 for cable tray hardware were all accepted after, date of speed letter memo o v January 29,1981, based on the blanket certificate of conformanc s This item is unresolved pending NRC review of a licensee evaluation and

clarification of conflicting requirements for cable tray hardware acceptance (443 and 444/82-03-01). *

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, Qualification of Flame Retardant Class IE Cable The inspector reviewed pertinent cable qualification test data to determine compliance with NRC requirements and licensee commitments. The inspectors reviewed the following documents:

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-- Franklin Institute Research Laboratory Report Nos.F-C4836-2 dated January 1,1978, F-C4969 dated July 1978 and attachment No.2 to the above reports number 8028 Anaconda Certified Test Report No.81-338-2-1 for cable specification No.9763-006-113-1 Purchase Order No.SNH-154-9763-006-113 The inspector noted that the specification calls for a color-coded, flame retardant jacket. A review of the above documents and discussions with licensee personnel indicate that the cable flame tests did not include samples of color-coded cabl This item is unresolved pending the 13 Tesee presentation of test data or other evidence regarding the accep'd 4?ity of the color coding material with regard to its flame retardant overt es {443 and 444/82-03-02). Seismic Qualification of Cable Tray The inspector reviewed cable tray specification No.9763-006-109-1 dated October 4,1976 and revision 2 of specification dated January 9,1978. The inspector noted the imposition of NEMA-VE-1 standard practices in addition

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tospecificIrequirementsdefinedinAppendixBtoSpec.109-1. Figure 1 of Appendix B illustrates 10 ft. straight section of cable' tray in a fully clamped position for the load test. VE-1-2.03, item 1 of the NEMA standard indicates length of straight sections as 12 ft, plus or minus 3/16 inch and 24 ft. plus or minus 5/16 inch. Paragraph ~B, Part 3, of the NEMA test standard states that the test span shall be simple beam spans with free-unrestrained ends. Discussions with the licensee indicate that the cable tray qualification was questioned by the NRC in NRC Inspection Report No.443/81-09, followed by an audit by the licensee's representative in the area of tray qualificatio This item remains open (443/81-09-03) pending NRC review of Lthe resolutions to-the audit finding . QA Program for Cable Tray The inspector examined completed work and partially completed work pertaining to the Unit 1 safety-related cable tray installation to ascertain wb:ther related activities were performed in accordance with NRC requiremen';q and licensee SAR commitments. Cable tray examined for this determinati include:

-- Cable Tray Nos.26Y1RC, 26Y2RC node no.0601 - elevation 50'-0"

-- Cable Tray Nos.26X1RC, 26X2RC node no.2649 - elevation 50'-0"

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-- Cable Tray No.17UIRB - elevation 50'-0" 2 inspector observed that the above trays contained discrepancies which, if identified in the Vendor Surveillance Check Plan - revision 3 dated June 6,1980, would have constituted rejection criteria. Specific items identified by the inspector are:

-- broken weld (tray no.17UIRB)

-- g1p between rung and side rail flange greater than 1/8 inch

-- weld buildup under rung leaving gap between rung and side rail flange

-- splice plates do not conform to bend of fittings, making it impossible to use all bolt holes in the splice plate Discussions with licensee representatives regarding the adequacy of the

quality assurance program for raceways indicate there is no formal program to l inspect the raceways for the types of problems identified by the inspector i during or after installatio Quality assurance requirements established

by MM-5788-A of May 9,1980 and clarified in memorandum of the same date indicate a) the licensee will rely on a certificate of compliance, shop inspection of the catalog item or receipt inspections of the catalog number; b) inspection shall consist of normal visual inspection on delivery to

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verify that the items have been received undamaged. In addition, item 4 of the above memo states that the QC inspectors will perform surveillance /

normal in-process inspection for safety-related installations, relying on the craftsman to find obvious defects during installation and take corrective action. The memo also implies that the raceway and raceway components are commercial grade and do not become safety-related until incorporated into a tray support syste The licensee position in not establishing an inspection program for raceways is inconsistent with the findings identified in noncomformance report FBM-004 dated'Jun~e 11,1979. The report documents the results of a random inspection

of cable trays and fittings. The report identifies eighteen (18)

discrepancies in the manufacturing process of cable trays that required extensive rework and eight (8) problem areas in joining the various sections of bottom trays and fitting The Seabrook Station FSAR commits to Regulatory Guide 1.30, revision 0 dated August.1972 which requires that safety-related systems comply with IEEE-336-197 IEEE-336, section 1.1.1 states, in part, that: "In addition to the Class I and Class IE systems, the requirements also apply to the following auxiliary equipment that are a part thereo (1) Connecting Cables and Raceways."

The inspector informed licensee site management and QA personnel during an exit interview on March 26,1982 that the failure to establish an adequate inspection program for installed cable tray verification in line with

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IEEE-336 commitments, represented a violation of 10CFR50, Appendix B, Criterion X (443 and 444/82-03-03).

9. Containment Building Unit 2 - Work Observation Exterior Wall-Reinforcing Steel /Cadweld Splice Installation I

The inspector observed work activities for the containment exterior wall including reinforcing steel installation and cadweld splicing of

number 14 and 18 size vertical and horizontal grade 60 steel. The NRC inspector evaluated these activities for conformance to criteria identified in the FSAR and its referenced standards, UE&C specifications and drawings, Perini implementing quality control procedures and ERICO instructions for cadweld splicing. The fabrication of completed vertical splices at the top of base mat and horizontal hoop splices in the first concrete wall lift above the mat were verified for centering, i end voids and stagge The inspector discussed cadweld stagger conformance to the Bethlehem Steel detail drawings and soecifications with the contractor's QC supervisor, UE&C Civil supervisor, and the YAEC QA 4 enginee No items of noncompliance were identified.

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. . 11 b. Interior Slab at (-26) Elevation /0bservations After Placement and Placement Record Review A containment building (elevation -26) interior slab was placed during March 11 and 12. The inspector observed significant fe:tures of the completed work, reviewed contractor drawings for confomance to the engineering details, and discussed with QC engineers and supervisory craft personnel the placement scheme and practices used in placing and consolidating the concrete. The inspector observed the finished floor surface, the dowel steel, to include spacing, size, length and clearance and the slab / containment liner separation. Additionally the inspector verified conformance of rebar installation and workmanship during installa-tion of vertical and horizontal reinforcing steel for future interior walls above the sla .

The inspector performed a record review of the elevation (-26) slab concrete placement activities to verify compliance with FSAR commitments and referenced codes and standards. Concrete placement activities were evaluated for confomance to criteria identified in :

-- Job Specification 13-2, Containment Concrete Work

-- Job Specification 5-1, Civil Testing Facility and Services

-- PPC Quality Control Procedures:

- QAP 10.4, Concrete Batching, Delivery

- QAP 10.5, Concrete Pre-placement and Post-placement Inspection

- QAP 2.0, Quaiification and Certification of QA Personnel

- QAP 10.0, Qualification and Certification of Concrete Productio'n Facilities

-- PPC Field Civil Construction Procedure - FCCP 2, Formwork and Handling, Placing, Curing, Finishing and Repair of Concrete

-- PTL Quality Control Procedure QC-FSTC-1, Field Sampling and Testing of Concrete, and PQ-2, Qualifications for Inspection and Testing Personne Pertinent work and quality records associated with the estimated 2,210 cubic yards of concrete placed by pump line conveyance in the containment building elevation (-26) slab were reviewed by the inspector. The following documentary evidence was reviewed to ascertain whether the records are in conformance with the above procedures and whether the records reflect work accomplishment censistent with applicable requirements in the following areas:

- Preplacement preparation and sign-off by craft supervision; engineer check-out; QC inspection reports on preparation, concrete placing scheme / equipment, manpower and contingency preparedness; " satisfactory" QC preplacement inspection report and UE&C release for concrete placement S - Concrete placement inspection report

- Concrete batching, truck delivery tickets, and testing of grout and concrete sampled at end of pump line

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- Grout cube and concrete compressive strength cylinder test reports

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QC verification of above activities

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Complete and legible nonconformance reports with corrective action specified and approved No items of noncompliance were identifie . Reinforcing Steel /Cadweld Curved Bar Sister Splice Testing The two options available for tensile testing of cadweld splices include production splice or sister splice sampling as identified in ASME III, Division 2, Section CC-4333.4 and Regulatory Guide 1.10. The Unit #1 containment building has reached the dome, where only curved bars exis ASME III, Div.2 considers this condition and specifies that straight sister splices shall be substituted for. production samples on radius bent bar However, this code does not contain a requirement on the testing frequency when only sister splices are made by a crew of cadweld operators. UE&C has provided an interpretation intended to fill the lack of specific guidance in this area as follows:

Where cadweld operators are splicing only radius curved bars (Reg. Guide 1.10

" curved bars"), UE&C proposes that crews fabricate straight sister splices for tensile testing. The frequency suggested by UE&C for all sister splice tests is that given in the Reg. Guide when crews are fabricating combinations of straight and curved rebar splice The inspector expressed a concern that UE&C's interpretation does not completely satisfy Code and Reg. Guide requirements:

-- Code CC4333.4.3(c) - Bars bent with large radii shall be considered straight bar Reg. Guide 1.10 (4) - For each splicing crew at least one-fourth of the total number of splices tested should be production splice UE&C maintains the position that deviation from the latter requirement is unavoidable for crews working only on curved bar splices, since only sister samples are take Pending further licensee review and acceptance of this UE&C interpretation and NRC review of the apparent Code deviation, this item remains unresolved (443 and 444/82-03-04).

11. Ground Water Leakage - Review of Unit 1 Noncomfomance Reports and Unit 2 NCR on Equipment Vault Membrane Leak Perini NCR 1667 dated May 15,1981 identifies leakage of water through concrete

. . 13 cracks in the diesel generator north and south bay walls above elevation (-16) and (-8.5) floor Exterior wall waterproof membrane was incomplete at this time. Weekly crack inspection checks were prescribed as required interim action as additional membrane was added and attempts were made to seal all a,las where water could enter behind the membrane. NCR 1667, Revision 1, dated October 2,1981 identifies a program of continued checks after membrane completion. Surveys of the hairline cracks indicate that some leakage still exists and a recommended disposition of the NCR by UE&C was not available at the time of this inspection. NCR 468 also identifies water leaks in the Unit 1 equipment vault at elevation (-61). The Unit 2 equipment vault is identified in NCR 1582, dated March 12,1981, as having water build-up inside the membrane envelope, even though the Unit 2 dewatering system is in operatio Studies have been undertaken on Unit 2 to detemine the source of the water. However, disposition of the NCR was also not availabl The NRC inspector discussed these issues with licensee representatives and indicated that the FSAR in section 3.4.1.1 on Flood Protection Measures for Seismic Category I Structures states that potential in-leakage from floods is prevented by water-proofing on the exterior face of structure Since the present conditions indicate either known water leakage or potential membrane damage, disposition of the aforementioned NCRs must address appropriate corrective actions. Pending a review of those actions by the NRC, this item is unresolved (443 and 444/82-03-05).

12. Reactor Coolant Pipe Welding (Unit 1)

The inspector observed welding on three reactor coolant pipe joints using the Dimetrics auto-GTAW process. Weld material was checked and traced to the receiving point on site. A sample of electrode / rod material test reports was reviewe He also inspected ID grinding in proces The inspector interviewed welders, examined the delta ferrite measurements

for several completed and in-process welds, and reviewed documentation of weld

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shrinkage history and field weld process control, including hold point inspection.

! General QC coverage of the Dimetrics welding program was discussed with l licensee personnel. The inspector verified the intent of the contractor to ( provide inspection of the overall welding process beyond that required by i specified hold points.

I No items of noncompliance were identifie . Support Installation (Units 1 and 2) The inspector examined several instrumentation tubing supports in the Unit 1 Primary Auxiliary Building (PAB) and the Unit 1 and 2 mechanical rooms of the cooling tower; several electrical conduit and cable tray supports in the Unit 1 PAB and "A" & "B" electrical penetration tunnels; and one pipe support (833-SG-6) in the Unit 1 PAB south equipment vaul Design drawings and Engineering Change Authorizations (ECA) were reviewed and the QC status and inspection document packages spot-checked.

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. . 14 All of the instrumentation supports were in conformance with design drawing, UE&C specification (46-1), and JCI procedural requirement Weld appearance and identification, member sizes, and concrete anchor installations were all of acceptable quality and the work and inspection packages provided evidence of good contractor control of tubing support erection. Discussion with UE&C engineering personnel and a review of UE&C Pipe Support Design Guidelines verified that base plate flexibility (ref: IE Bulletin 79-02) had been considered in the design of concrete anchor-bolted tubing supports and their design modification The electrical supports were noted to have bolt / nut components supplied by varying manufacturers, as is discussed in paragraph 3b. of this report. Also certain 33DL fitting attachments anchor bolted to the wall were found by the inspector to have the Hilti washer bent into the slotted fitting hole by the required torque application. Upon notification of the licensee, UE&C ECA 03/1628A was issued providing adequate instructions for this problem fix and retrofi However, upon examination of surface mounted strut configurations for conduit supports in the "B" train tunnel, nonconformance to the design details of ECA 03/1067F was identified (eg: support 4244). Where a washer of 3/32" minimum thickness was required, washers of thinner thickness had been installed. This in combination with use of the slotted-back struts and the turquing operation caused visible deformation of the thin washer into the slot. These supports had been accepted by FBM QC inspection, even though the intent of the ECA modification was to

" avoid strut deformation and washer bending". Later inspection by contractor personnel revealed this to be a generic proble Upon examination of pipe support 833-SG-6 to the details of its Pullman hanger drawing (Revision 3A), the following nonconforming conditions were identified:

-- shorter length of W8 beam than required causes supported member overhang and decrease in detailed fillet weld lengt bottom flange of W8 beam is skewed h" requiring stiffeners of two different size cutting of W8 beam to avoid elevator interference does not confonn to the modification required by ICA 28/0007A and also resulted in reduced weld length (Note: this third item was identified during a reinspection by licensee QA personnel generated by the NRC inspector's questions).

The Pullman inspection package for support 833-SG-6 was reviewed and revealed that welds and member conformance had been accepted by QC personnel. The inspector also noted that a nine month interval passed between QC hold point inspection of tack welds and final welding, without any evidence of reinspection of the condition of the tack welds. With regard to this last item the licensee and contractor committed to revision of existing procedures to require no more than a four-day time lapse

. . 15 between inspection of tack welds and incorporation of those tacks into the final wel With egard to the noted nonconfonning conditions on pipe support 833-SG-6,'as well as the noted nonconfoming washer on surface mn"-ted electrical struts _ governed by ECA 03/1067F, the inspector detennined that

inadequate QC inspection had been provided, based upon visual evidence ' >

of the nonconfonning conditions. -He informed the licensee Site Manager and Field QA Manager during an exit interview on May 3,1982 that this failure of the QC inspection process represented a' violation of 10 CFR 50, Appendix B, Criterion X ~ (443/82-03-06). The inspector reviewed the site concrete expansion anchor installation-program, discussing details with QA and engineeriag personnel, spot-checking training, and examining the' following documents:

-- UE&C Specification 18-17 (Revision 2)

-- Hilti Architects and Engineers Anchor and Fastener Design Manual

-- Certain contractor procedures for Installation & Inspection of Concrete Anchors

Concrete expansion anchors at Seabrook are Hilti kwik-bolt stud anchor The. inspector verified procedural operations including method of instal-lation, torquing, and inspection points. The examination of several supports addressed in paragraph a. above presented the opportunity to inspect Hilti kwik-bolt installations for minimum embedment depth, hole depth, material conformance, and torque seal applicatio While no items of noncompliance were identified, a question with generic implications was raised as follows: Hilti and site procedures provide for minimum anchor spacing of ten diameters to preclude shear cone interaction from reducing the design tension loads of each bolt when used in combinatio It has been noted that at embedment depths of "about 51s diameters",

the mode of failure changes from shear cone to pull-out, thus eliminating the need for increasing minimum spacing for anchors of greater embedmen However, the test data submitted by Hilti does not fully justify this position. For certain size anchors at certain embedment depths, multiple bolt connections will have shear cone interaction when spaced at ten diameters. Thus, using individual anchor allowable tension loads from the Hilti data for multiple connections with these questionable anchors would not be precisely correct. While UE&C feels that further evaluation will justify the design assumptions here at Seabrook based upon additional site test data which exceed the Hilti values, the generic implications of this question merit resolution by Hilti. Pending clarification of the inconsistency of the test data with the general minimum spacing criteria, this item is unresolved (443/82-03-07 and 444/82-03-06).

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14. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviation Unresolved items disclosed during the inspection are discussed in Paragraphs 5,6,10,11,and 13 . Management Meetings

' At periodic intervals during the course of this inspection, meetings-were held with senior plant management to discuss the scope and findings of this inspectio On April 8,1982 a management meeting with senior licensee personnel (See Attendance List in paragraph Ib.) was held at Seabrook Station to discuss corrective actions taken in response to NRC concerns in the design and design change control areas. The following recently instituted licensee actions were noted:

-- establishment of an ECA task force

-- A/E site engineering reorganization

-- initiation of an A/E Engineering Assurance audit program

-- increased YAEC engineering program and audit participation The NRC staff plans increased attention to and inspection effort of these issues.

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