IR 05000397/1980011
| ML17275A588 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/21/1980 |
| From: | Engelken R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17275A586 | List: |
| References | |
| 50-397-80-11, NUDOCS 8009150379 | |
| Download: ML17275A588 (18) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No. 50-397/80-11 Docket No. 50-397 License No.
CPPR-93 Licensee:
Washington Public Power Supply System P. 0.
Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project Unit 2 (WNP-2)
Meeting at:
NRC Region V, San Francisco Meeting conducted:
August 12, 1980 Report By:
.
D. Tot Ress ent Inspector R
p g/ g'e Date Soigne Approved By:
R.
H.
Enge en, DsreCtor r/si/Z o Date Soigne Summary:
Mana ement Meetin Au ust 12, 1980 Re ort No. 50-397 80-11 This was a special corporate management meeting to present to R. L. Ferguson, newly appointed Managing Director of the Supply System effective August 1, 1980, the results of NRC Region V evaluation of licensee performance for the period of April 1979 through July 1980.
This review encompassed data presented in a similar meeting of May 20, 1980 and included review of subsequent inspection and investigation findings.
Specific areas of NRC concern were discussed, as well as planned NRC actions regarding WPPSS restart of work which had been subject of NRC immediate action letters.
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DETAILS 1.
Meeting Attendees Washin ton Public Power Su pl S stem R. L. Ferguson, Managing Director D. L. Renberger, Assistant Director, Technology F.
D. McElwee, Assistant Director, Projects M. W. Hultgren, Manager of Projects W.
C. Bibb, Project Manager - WNP-2 M. E. Witherspoon, Division Manager, equality Assurance Nuclear Re ulator Corrmission - Re ion V R. H. Engelken, Director G. S. Spencer, Chief, Reactor Construction 5 Engineering Support Branch R.
C. Haynes, Chief, Reactor Projects Section, Construction R. T. Dodds, Chief, Engineering Support Section, Construction J. L. Crews, Chief, Reactor Operations Branch D. M. Sternberg, Chief, Reactor Projects Section 1, Operations A. D. Toth, Resident Reactor Inspector, WNP-2 T.
W. Bishop, Resident Reactor Inspector, WNP-3/5 J.
H. Hanchett, Public Affairs Washin ton State Senate Senator T. Bottiger, Chairman, Senate Energy and Utilities Committee Senator S. Gould, Ranking Republican, Senate Energy and Utilities Committee C. Eschels, Senior Research Analyst, Senate Energy and Utilities Committee Energy Facilit Site Fvaluation Council F. Hahn, Chairman, Monitoring Committee G. Hansen, Staff Engineer Bonneville=Power Administration J.
R. Lewis, Project Engineer - WNP-2 2.
NRC Position Statement The NRC Regional Director described the Inspection and Enforcement mission and the potential impact on the issuance of a WNP-2 operating licensee.
He noted that over the past two years NRC has repeatedly expressed concerns
j
over the ineffectiveness in the implementation of the WPPSS quality assurance program and inadequate control of contractor activities.
He stated that the November 21, 1979 NRC Stop Work letter and the June 17, 1980 Notice of Violation, Civil Penalty, and
CFR 50.54(f) letters set forth the NRC position on these matters and the required corrective actions.
The Director emphasized the need for strong management attention by WPPSS to these problems.
3.
General Areas of NRC Concern The following items were identified as specific and general problem areas which appear to exist for the WNP-2 project:
a)
Contractors with significant quality deficiencies had been allowed to perform quality class 1 work.
b)
Excessive time required to correct identified deficiencies.
c)
Large inspection backlogs for completed work.
d)
Poor site records control.
e)
t1ultitude of site contractors having independent quality assurance programs.
f)
Assignment of quality assurance staff with lead responsibility for contractor work compliance.
g)
Overly complex and over-committed procedural requirements.
h)
Inadequate indoctrination of personnel.
i)
Inadequate pre-planning and preparation.
j)
Inadequate feedback of problems to first-line personnel.
4.
Enforcement Histor The Region V staff discussed the enforcement history and apparent trends for WNP-2.
Inspection finding versus manhour statistics indicated that it has recently taken less effort for NRC inspectors to identify problem areas on this project as compared to other projects in Region V.
(See Attachments 1 and 2).
A review of NRC inspection findings show uncorrected or repeat items and cases where procedures which were to control work were not in place prior to start of the work.
(See Attachment 3).
A review of events associated with the sacrificial shield wall and pipe-whip restraint problems since 1975 show that several opportunities were presented wherein WPPSS could have identified and corrected the significant uality assurance program deficiencies which were recently found to exist.
See Attachment 4).
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5.
Recent Investi ation/Inspection Results In early 1980, a Washington State Senate Investigating Committee interviewed various MNP-2 project personnel regarding project cost matters.
Various statements obtained appeared to relate to construction quality matters and these were verbally conveyed to NRC headquarters personnel.
No written allegations were submitted by MNP-2 personnel in this regard.
The NRC considered first 38, then an additional 7 items as areas of concern.
A Region V inspector-investigator-supervisor team then spent 780 man-hours on-site, and in the vicinity of the site, conducting further interviews and inspecting hardware and records.
The NRC Director of the Office of Inspector and Auditor attended interviews on several days to assess the potential for any criminal activity.
The period of interest for the investigation into work/records was 1978 to present, relating to on-site mechanical contractor activities.
A total of 12 apparent items of noncompliance, 7 unresolved items and 21 open items requiring followup action were identified by the investigation team (see attachment).
The results of the investigation reinforced the earlier conclusions described in the NRC June 17, 1980
CFR 50.54(f) letter, regarding need for management action.
6.
Work Restart Pro ram The Region V staff discussed the events and requirements for restart of site construction activities, the need for adequate procedures, preparation of personnel, and completion of other prerequisites was noted.
Relative to NRC imposed constraints, the following actions are anticipated:
1)
Region V November 21, 1979 Immediate Action Letter regarding sacrificial shield wall:
WPPSS plans to submit data to NRR to supplement the HPPSS/NRC August 6, 1980 meeting presentation.
Following the NRR review, Region V will issue a letter acknowledging the satisfactory completion of this condition (i.e. comprehensive corrective action plan) stipulated in the IAL.
2)
NRC July 18, 1980 letter regarding contract
~9215:
The NRC Senior Resident Inspector at HNP-2 will examine the results of the WPPSS re-evaluation of detailed work methods and associated corrective action plans for contract 8215.
Following this review, Region V
will issue a letter lifting the work restart constraint.
3)
NRC June 17, 1980 letter regarding
CFR 50.54(f):
The NRC resident inspector and Regional Office based inspectors will routinely review the implementation of the commitments described in the above letter.
The results of these reviews will be documented in monthly inspection reports.
The resident inspector at HNP-1/4 was transferred to the HNP-2 specifically to provide close followup of these activities.
The inspector is not, however, part of the HPPSS review/approval chai Hith regard to HPPSS plans submitted in response to the flRC letter, the NRC staff cautioned that the described reviews be more than paper reviews, and include meaningful hardware inspections.
7.
Conclusion The HRC Regional Director expressed the view that HPPSS can recover from the problems discussed at the meeting, although close management attention will be required.
The HPPSS l1anaging Director noted that he will be personally involved in this matter and will keep the Region Y office informed.
He indicated that HPPSS will particularly re-evaluate how HPPSS does business with its contractor ATTACHMENT 1
~LOP-XFORC NT HISTORY DESIGN, PROCUREMENT, 8I CONSTRUCTION
2500
ITEMS OF NONCOMPLIANCE
'I III-100
"90 2000 0
CL C)
CD
~~ 30
10
//
REASSESSMENT
/f BY lrlPPSS I
CONSTRUCTION PROGRESS
/
I I
I I
i+INSPECTION HOURS
/I/III//////
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I t
1500 C 1000 500
70
)60 W
CL,
-50 o I-40 Yc LU
-20 INSPECTION MANHRS PER NONCOMPLIANCE 33HR 39'HR 142llR 5 1HR 2 1HR NC NC NC NC NC
'71
'72
'73
'74
'75
'76
'77
'78
'79
'80
. '81
'82 YEAR-10
NRC RV NFORC NENT CTIVITY DESIGN, PROCUREMENT, 8( CONSTRUCTION (AVG.
OF
MOS.
PRECEDING 7/80)
150 C)
~ 100-UJ CY C)
I UJ CL C/l
0 PROJECT A
PROJECT
TTACHMENT 3 ITEt1 TYPE*
WNP-2 ENFORCEMENT HISTORY DESCRIPTION REPEAT Failure to maintain cleanliness JCI Failure to monitor weld preheat Failure to maintain inspection status Failure to properly code electrical cables Failure to properly install battery racks
12
14
17
19
Failure to properly identify circuit breakers Failure to qualify PWHT procedure Failure to provide procedure for PWHT Failure to maintain records of PWHT Failure to PWHT per ASHE Code Failure to maintain system cleanliness F/L Failure to maintain system cleanliness JCI Failure to provide class I-E equipment for RPS Failure to properly weld SSW Failure to maintain system cleanliness F/L 5 JCI Failure to provide SSW UT procedure Failure to provide PWR UT procedure Failure to provide SSW Heat straightening procedure Failure to provide PWR heat straightening procedure Failure to provide SSW weld sequence procedure
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ATTACHMENT 3 (Continued)
NNP-2 Enforcement History ITEJl
22
24
27 TYPE*
DESCRIPTION Insufficient SS'lJ records identification of Inspection personnel Insufficient SSIJ records-inconsistent information Insufficient Pl JR records identi ficati on of inspection personnel Insufficient PlJR records
- inconsistent NDE reports Insufficient PlJR records
- incorrect inspection identification Insufficient Pl(R records incorrect inspection identification Failure to qualify PlJR inspection personnel REPEAT
29 Failure to personnel Failure to qualify SSlJ inspection control weld filler material
31
33 Failure to repair per AMS Failure to properly UT PNRs Failure to properly inspect pipe supports Failure to document weld inspection
- V = VIOLATION I =
INFRACTION
= DEFICIE[JCY
ATTACHMENT 4
'HNP 2 SACRIFICIAL SHIELD HALL/PIPE 1<HIP RESTRAINT CHRONOLOGY 1975 CONTRACTOR GIVEN APPROVAL TO START FABRICATION OF SHIELD WALL 7/76 NRC INSPECTION OF SHIELD WALL SITE ERECTION ACTIVITIES NONCOMPLIANCE-LACK OF QUALITY PROCEDURES 7/76 STOP WORK ISSUED, SITE ACTIVITIES AUDITED BY CONTRACTOR/BURNS
& ROE 8/76 CONTRACTORS SHOP ACTIVITIES AUDITED BY BURNS
& ROE/WPPSS 6/78 CONTRACTOR CERTIFIES SACRIFICIAL SHIELD l'JALL COMPLETE 10/78 VOIDS DETECTED IN SHIELD 1JALL BY 215 CONTRACTOR 1j/78 215 CONTRACTOR IDENTIFIES NUMEROUS DEFECTS, ASKS WPPSS TO RE-EVALUATE THE SHIELD WALL 2/79 WPPSS NOTIFIES NRC OF MAJOR WELD DEFECTS FOUND IN BRACKETS FABRICATED BY THE SHIELD WALL CONTRACTOR
$/79 BURNS
& ROE ESTABLISHES PLAN TO ASSESS SHIELD WALL ADEQUACY 6/79 NRC RECEIVES ALLEGATIONS REGARDING SHIELD lJALL AND REPAIRS, INSPECTORS IDENTIFY GAP BETWEEN RINGS, QUESTION RECORDS 7/79 7/79 10/79 lJPPSS COMMITMENT TO NRC TO REVIE'rJ ALL SHIELD WALL QUALITY RECORDS 215 CONTRACTOR INITIATES QUALITY REVIEW OF SHIELD WALL CONTRACTOR lJPPSS REPORTS TO NRC THAT SHIELD WALL IS NOT PROPERLY WELDED TOGETHER 10/79 NRC REVIEW OF BURNS
& ROE EVALUATION ACTIVITY REVEALS THE EVALUATION IS BASED ON INCOMPLETE DATA (TYPICAL VS ACTUAL DEFECTS)
WPPSS NOTIFIES NRC OF RECORDS IRREGULARITIES IN PIPE WHIP RESTRAINT RECORD PACKAGES (SAME CONTRACTOR AS SHIELD WALL)
NRC ISSUES IMMEDIATE ACTION LETTERS, WORK STOP ON SACRIFICIAL SHIELD lJALL AND PIPE WHIP RESTRAINTS J'JRC INVESTIGATION OF SHIELD HALL/PIPE WHIP RESTRAINT CONTRACTOR'S 2/8O PROGRAM AND RECORDS,
ITEMS OF NONCOMPLIANCE
C
WNP-2 REPORT NO. 50-397/80-08 NONCOMPLIANCE/UNRESOLVED/OPEN ITEMS LIST TRACK NO.
PARAGRAPH ITEM
02
04
06
08
10
13
16
18
20
3 ~ a 3.b(1)
3.c 3.d 3.e 3.g 4.b 4.c(1)'.c(1)
4 c(4)
5.a(1)(a)
5.2(2)
5.b 5.c 5.d 5.e 3.5(l)(b)
3.d(l)(b)
5.e 5 '
6.a8 b
Infracti on Deficiency Unresolved Open Open Unresolved Deficiency Open Infraction Open Infraction Open Open Unresolved Open Infraction Unresolved Open Open Open Open Organizational freedom of QA/QC Survey document of vendor not maintained Acceptance criteria for recei ving inspection of hangers Licensee to examine proqram for documenting
'nspection findings Work continued on a support FDR-385 after issuance of a NCR Welds being cut out rather than repaired to preclude B/R review Failure to document inspection findings relative to incorrect amperage settings for NT probes WP-57 does not address the removal of temporary weld attachments Failure to maintain records for temporary weld attachments Form NF-286 contains note that temporary welding records will not necessarily form a part of permanent documentation Piping support clearances in excess of requirements Inspectors to be instructed to request engineers review of fillet welds on curviture of pipe Licensee to consider reportability of welding problems related to Pybus steel Control and documentation of arc strikes on structural steel Licensee to consider generic problem related to lack of penetration in pipe from Associated Pipe Failure to use filler metal specified in procedure Dispositioning of questionable filler metal and corrective action Disposition of pipe in quaranteen, heat numbers N12476 and N12477 Inconsistency in purging procedure for socket welds Question of reportability of problems related to the anchoring of support base plates Handling of pipe minimum wall thickness problems
Noncompliance/Unresolved/Open Items List TRACK NO.
PARAGRAPH ITEM
23
25
27
29
31
33
35
37
39
6.b(3)
7.a 7.b(6)
7.C Defici ency Open Open Open 7.c 7.g Open Open 7.h S.a, b
8 c S.a Unresolved Infraction Open S.b 9.a 9.b Open Open Open 10.c Unresolved 10.g Unresolved ll.a 8 ll.k(b)
Deficiency 11. a Deficiency 11. a Infraction 7.a Infraction ll.a, h
8 k(6)
Open Incorrect acceptance standards used to evaluate results of LP examinations WBG gAP-7 does not require owner approval of contractor procedures and revisions Establishment of controls to coordinate hanger material identification Control of certain heats of pipe in quarantine as identified in surveillance report No. M-246 Heat number is missing from pipe spool RHR-2018-1 Pipe with an apparent legitimate heat number has been installed, but has the word
"scrap" painted on it Difference between stores requisition records and laydown inventory records Calculations were not provided to support deletion or redesign of support welds Page 1 of Engineering guality Audit is missing from documentation package for support RCC-3 Inspection/control of oversized support steel fillet welds Followup on cleanliness of pipe being installed Review of system flashing procedures during preoperational inspections since flushing not planned prior to hydrostatic tests Calibration of torque wrenches and for tightening of Velan valves in pump house (NCR-5163)
guestion relative to the satisfactory removal of a ladder that had been tack welded inside MS-528-7.10 pipe spool Failure to provide a procedure and/or checklist for document review of work packages Failure of gA Manager to review records of rework that was performed subsequent.to the document package acceptance review Failure to perform weld inspection as required by procedure General review of licensee's action to assure final document reviews are properly accomplished, including commitment to the NRC on document review Failure to comply with procedure revision requirements