IR 05000397/1980018
| ML17275A810 | |
| Person / Time | |
|---|---|
| Site: | Columbia |
| Issue date: | 12/11/1980 |
| From: | Haynes R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17275A809 | List: |
| References | |
| 50-397-80-18, NUDOCS 8101290646 | |
| Download: ML17275A810 (15) | |
Text
U. S.
LiUCLEAR REGULATORY COi~MISS ION OFFICE OF INSPECTION AND ENFORCEMENT No 50 397/80 1 8
REGION V
Docket No.
icense
~o CPPR-93 Licensee Washington Public Power SupplY SYstem P.
0.
Box 968 Richland, Washington 99352 Facility Name:
Washington nuclear Project No.
2 (MNP-2)
Insoection at HNP-2 Site, Benton CountY, Washington Sazeguards Group Inspectors:
October 1-31, 1980 o
,
en>or ss en eac or nspec or Jec~~c /
Date Si,gned Date Signed Approved 3y:
Summary:
R.
C.
Haynes ie, Reactor Projects Section, Reactor Construction and Engineering Support Branch Date Signed
)I >>ll.r98ci Date Signed Ins ection on October 1-31, 1980 Re ort No. 50-397/80-18
~A<<:
i, di i
fli d
activities to re-evaluate and improve detailed work methods for installation of safety related equipment.
The inspection involved 114 inspector-hours on-site by the NRC resident inspector.
Results:
No items of noncompliance or deviations were identified.
RV Form 219 (2)
DETAILS Persons Contacted:
Washin ton Public Power Su
S stem WPPSS R.
G. Matlock, WNP-2 Program Director W.
C. Bibb, WNP-2 Project Manager A.
M. Sastry, Deputy Project Hanager, Systems Turnover R.
M. Foley, Deputy Project Manager, Engineering D.
C.
Timmons, Director, Contract 215 Engineering T. A. Gross, Management Systems Task R. T. Grant, Acting Supervisor, Restart Phase I
- B. A. Holmberg, Special Projects
- R. I. Johnson, Ouality Assurance Manager Burns and Roe En ineers BSR
- M. B. Tuthill, Assistant QA Manager Bechtel Power Cor oration'(PBC)
F.
B. Damerval, Reverification Manager D. Johnson, Quality Control Manager Pittsbur h Des Moines Steel Co.
PDM F. Warrington, Project Manager T. Foley, Manager-Quality Assurance
- Denotes personnel present at the exit interview.
Also, the WPPSS OA Manager met weekly with the resident inspector. to discuss current status of licensee activities and NRC inspection findings.
In addition to the persons identified above, the inspector routinely interviewed construction, engineering, and quality control personnel of various si te contractor organizations.
Project Personnel During this period the licensee implemented additional changes in the site organization developed in response to NRC's letter of June 17, 1980 concerni ng quality problems at WNP-2.
The three initial task forces have been consolidated under one manager, Hr. A.
M. Sastry, whose position is entitled, Deputy Project, Manager for System Turnover.
Also reporting to Hr. Sastry are Planning/Scheduling, Restart Coordination, and Administrative sections.
Mr. T. Gross was assigned as Management Systems Specialist of Task III to perform analyses of existing WNP-2 management control systems relative to findings from Task Group I
(evaluation of backlog problems)
and Task Group II (work reverification reviews).
Mr. F.
B. Damerval (Bechtel)
was assigned as manager of the reverification program.
Individual construction coordinators have been assigned to the major contractors to coordinate restart efforts between the contractors and Mr. Sastry's organization.
Within the mechanical contractor's organization, the following significant personnel changes were effected:
M.
H. Brenner Project equality Assurance Manager R.
M. Uric - guality Control Manager L. L. Keane - Procurement guality Assurance Manager-P.
Webster - Ouality Assurance Engineering Manager (Restructured Section)
M. Meade - Special Projects Manager
. General During this period, the inspector examined licensee and..contractor efforts to re-evaluate and improve detailed work methods for installation of safety related equipment.
The inspector attended briefing sessions conducted by licensee (HPPSS). personnel, briefing and working sessions of the mechanical. contractor (llBG}, hand meekly discussions with the WPPSS site (}A manager,.
The inspector also interviewed various management and staff personnel of HPPSS and the mechanical contractor, examined interna]
memoranda of..- WPPSS and the mechanical contractor, examined letters issued by-WPPSS to site contractors, examined various working schedules and documents issued during meetings, and observed onsite work areas to ascertain the nature of work in progress.
Project Status The labor dispute has continued to effectively stop all.construction work at the HNP-2 site, with minor exception, since June.2, 1980.
The site contractors have continued to review records and revise work methods/procedures.
The architect-engineer has continued to work at reducing backlogs of open engineering questions and to disposition nonconformance reports.
The licensee hag continued to review/revise management controls and to. consolidate, task force activities.
The site efforts have been oriented toward restart of work and the licensee task force continued to review existing gnd revised contractor work procedures.
Licensee management attention has been focused upon organizing and documenting plans associated with restart of work.
The licensee and the mechanical contractor have not yet completed their reviews and preparations for the restart of safety related work by the mechanical contractor.
The l.icensee's stop work order on the mechanical contractor remains in effect;
5.
Establishment of Licensee WPPSS Task Forces at WNP-2 a.
General Three task forces were established by HPPSS in response to the quality concerns enumerated in NRC's letters of June 17, 1980 to HPPSS.
These task forces have been integrated into the HPPSS HNP-2 project organization under Mr. A.
M. Sastry.
b.
Task Force II-Reverification of Com leted Safet -'Related Work RCSW Previously completed safety related work performed 'by certain contractors is to be examined by HPPSS to assure that the work is acceptable.
Task force II was formed by WPPSS to participate in a major way in this effort.
Presently this task force is staffed with 50 personnel.
The workings of this task force is governed by an instruction manual containing two volumes.
Volume I of the manual contains ten instructions to control the woy.k of the task force members.
These instructions were reviewed by the NRC resident inspector.
Instruction No.
RCSH-05 was recently added to the manual to provide for a formal method to prepare, distribute and control reports of discrepancies identified during this task group's reviews.
This method permits such findings to be handled according to pre-established systens for dispositioning nonconforming items.
The following procedures in Volume I were reviewed.by the inspector and no departures from project OA,program requirements pere identified:
RCSH 01/1 Planning and Preparation of (A,Peverification Checklists.
RCSH 02/1 Administration and Control of OA Reverification Checklists.
RCSH 03/1 RCSH 04/0 Reporting Documentation Package Preparation Review and Submittal to Indeoendent Review Team.
RCSH 05/0 Preparation and Control of Discrepancy Reports.
RCSH 06/1 RCSH 07/0 Documenting Review and Comments for Procedures/
Documents Submitted to RCSH.
Identification and Reporting of Non-Contractor Problem RCSH 08/0 gualification and Certification of gA Personnel for RCSH Task Force.
RCSH 09/0 Processing of 10 CFR Part
and 50.55(e).Reports.
RCSH 10/0 RCSH Tickler System HPPSS has also prepared Volume II of the RCSW,Manual which governs the interfaces of this task force with other project organizations regarding the restart of safety, related work by site contractors.
Parts of this volume are in preparation.
The inspector examined the following procedures and no departures from project OA program reauirements wepe identified:
PJT-01 Restart Activities Scope
.PJT-02 (Draft)
System Turnover Organization and functional Responsibilities PJT-03 Waivers and/or, Modifications to restart Pre-requisites PJT-04 Scheduling and Information Flow PJT-05 RCSW Procedure Comment..Resolution PJT-06 PJT-07 PJT-08 Review of SAR Requirements Deficiency Review Problem Evaluation Program Actions-RFI, PED, NCR, and IR Backlogs PJT-09 Resolution of Non-Contractor Backlog PJT-10 Project Engineering Directive (PED) Review PJT-11 Corrective Action Requests Mana ement S stems - Task Force III Task Force III is now defined as the Management Systems function.
The individual assigned to this function has the task of promulgating lessons learned to various contractors at the HNP-2 site and to other WPPSS nuclear plant sites.
The operating orocedures for this function are in preparation.
It is expected that they will contain
=-
measures to disseminate information, but not mandate development of action plans or followup on such action plans.
The performance of this function will be subject to future review.
(397/80-18-01),
Functioninn of MPPSS Task Force II Task Force II appears to be functioning as described in the licensee's reply to the NRC.
Team leaders and personnel have been assigned for each major site contractor.
Although early activities of the teams led to problems in interfacing with other site organizations, the teams appear to have been able to perform their assiqnments.
These assianments included revieW of contractor procedures and qualifications of personnel.
Current Task II efforts are almost totally devoted to reviewing contractor programs for restart of construction work.. For the mechanical contractor, this effort has been mostly confined to reviewing contractor readiness to start the girth weld at rings 3 and 4 of the sacrificial shield wall (SSW).
The RCSW teams also plan to review records and hardware completed within 90-days of June 2, 1980.
However, for the SSW-weld, WPPSS has decided to waive the 90-day reinspection in view of the extensive reinspection already performed on this structure by the architect-engineer.
Instructions have not yet been prepared defining reinspection objectives and sampling cri teria for the reinspections of work completed within 90 days of June 2, 1980.
The RCSW.teams plan to utilize contractor work method procedures in their reinspections.
Where the contractor has recently revised his procedures, the teams expect to use the new procedures rather than those used -for the execution of the work.
The licensee has apparently recogni zed the need for instructions for these 90-day rei nspections.'"
These instructions will be examined during subsequent NRC inspections.
(397/80-18-02)
The RCSW teams have not yet begun the reverification inspections of work completed prior to 1980, and sampling and action level instructions are not yet complete.
Such instructions will be examined during future NRC inspections.
(397/80-18-03)
WPPSS Work Restart Hang ement Controls The licensee plans to evaluate the detailed work methods for construction work activities, each such work activity being labeled a "commodity item".
Forty-three commodity items have been defined and the RCSW teams have been scheduled to address each commodity i tem in an order of priority.
The priorities were established based on the construction schedule.
On October 21, 1980, the licensee met with RV at the NRC Region V
office and discussed the management logic network to be applied to the review of work methods for each. commodity item.
This network included many features developed by the site mechanical contracto The network included the following features:
a.
Reviews of NCRs, IRs, CARs, audits, and NRC findings are to be completed, and decisions incorporated into work procedures before commencing work.
b.
Review of planned work to assure that the work will not preclude reinspection of previous work.
c.
Crafts, supervision, engineers, and i.nspectors are to be trained in the use of the procedures before starting the work,.
d.
Personnel qualifications are to be Verified before starting the work.
e.
Mork packages will be-checked before release. to people for work.
f.
Material availability is to be verified prior to start of work.
Both MPPSS and the mechanical contractor have initiated reviews to assure that the controls implied by the network are jn fact in place before beginning work on the sacrificial shield wall girth weld.
That system of controls will be reviewed during future inspections.
(397/80-18-04)
8.
Hechanical Contractor's As-Built Activities In late October 1980, the mechanical contractor's field engineers were assigning craft personnel to check installation status of various piping and hangers.
The data was intended as. information,.for,.work,
.
restart manpower loading and scheduling decisions.
However, the data was being recorded on record copies of the construction drawings and was, therefore, a form of documenti ng the as-bui1.t status of the equipment.
The contractor's internal auditor identified that documenting of as-built work is to be controlled by procedures (which have been revised but not yet approved)
and nersonnel have not yet been trained to the procedures.
The contractor's auditor brought this matter to the attention. of the'construction manager who took immediate action to stop using record copies of, the drawings for this purpose.
Also, the tlPPSS gA manager declared his plans to review this as-built documentation work.
The inspector found that the mechanical contractor's audi t function worked effectively on this matter and construction management response was appropriat The mechanical contractor has completed a training procedure (WP-157) which has been reviewed and approved by the WPPSS review team.
The contractor has prepared lesson plans and conducted training session for supervisory personnel.
The training procedure reouires that all personnel be trained to the specific procedures which they will use, including craft, quality control, supervision and engineering personnel'ormal training with lesson plans and examinations are required.
A recent contract change had been issued by WPPSS to the mechanical contractor to further define training requirements.
A WPPSS re-review of WP-157 is expected when this procedure is implemented and,experience gained with its use.
10.
Containment Dr well and Wetwell Retrofit'Status The inspector reviewed the qualification/certification records of the fabricator's (Pittsburgh-Des Moines)
gC inspectors.currently engaged in the reinspection of completed work.
The records and/or supplemental interviews showed that each gC insoector was a high school graduate as recommended by Regulatory Guide 1.58 and inspectors were certified to SNT-TC-1A requirements, where applicable.
The inspector noted that the containment vessel was code stamped in Quly 1976, under ASME Section III, Class MC.
Repair and'etrofit activities have been performed under ASME Section XI which references the original construction code.
Applicability of the original code stamp and details of post-repair pressure test requirements are currently being evaluated by the licensee.
The licensee'.s resolution of these matters will be reviewed during a subsequent inspection.
(397/80-18-05)
ll.
Licensee Action on Previous NRC'Ins ection Findin s
a.
)01 d)
1 d
I
)391/3 -10-01): ~if throu h-wall-stress limitations'for Burns and Roe han er desi n
uide.
The inspector previously inquired as to where the 50K reduction i n allowable stress, as prescribed in Table 1-7-1 of ASME III-NF, has been considered for ASTM-A36 material.
The engineers reviewed the design guide basis and identified that this factor was considered indirectly through limitations placed upon base metal shear allowables per AISC Code.
Thus, load limits ca]culated from the ASME normal stresses at the fillet weld base ape comparable to the AISC shear stress analysis at the fillet weld throat.
The inspector had no further questions on this ite (Closed)
Followup Item (397/80-10-05)
Licensee im lementation of Task II activities of selectin review teams formulatin revi ew checklists, and riori ts zin contractor work acti vities.
As of October 9, 1980 the RCSW task force (Reverification of Completed Safety-related Work) had been staffed with 50 quality-control/quality-assurance personnel assigned to six review teams.
Review checklists have been generated and applied to r'eview of contractor procedures.
Contractor work activities have been prioritized to a list of 43 commodities.
An RCSW instruction manual has been prepared with summary instructions for functioning of the task force.
This item is considered to -be closed.
(Closed Unresolved Item 397 80-15-02 Specification.No.
215 limitation of han er o eratin loads to 10 000 lbs.
The Burns and Roe Resident Project Engineer issued Project Engineering Directive (PED)
No. 215-H-1308 which deleted paragraph 3. 11 from the specification, thus eliminating the constraint on operating loads.
The engineering representative stated that the original requirement assumed hanger design by subcontractors.
Since then, Burns and Roe engineers have designed special hangers exceeding this criteria, but with review and analysis by Burns and Roe civil/structural engineers.
The PED was issued to clarify the acceptability of such hangers, consistent with current design requirements and responsibilities.
(C1
)
"
i d
I t357/8
,16 06) g life of ins ectors for new work and reins ection of existin work.
The WPPSS project gA manager issued a set of instructions on October 9, 1980, to be used by.Task Force II in the evaluation of contractor training programs.
These instructions supersede the instructions of September 18, 1980, and incorporate the principal qualifications criteria of NRC Regulatory Guide 1.58 and ANSI-N45.2.6-1978.
The instructions include ASNT-TC-lA and ASHE requi rements, as applicable, and require on-the-job traini ng and examinations, including use of equipment and procedures.
Re-evaluation and records requi rements are defined.
The ANSI-H45.2.6, part 2.3 requirement for re-evaluation every 3 years is not incorporated, since the remaining project duration is expected to be less than 3 years.
The Regulatory Guide 1.58, part C.6 requirement for high school education has been specifically imposed for the level I personne],
and imposed by inference for level II and III personnel.
The instruction also recognizes the Regulatory Guide 1.58, part C.10 provision for performance capability testing in lieu of education and experience factors.
The i nspector had no further questions on this matter at this tim e.
(Open) Unresolved Item (397/80-08-03)
-
uestionabl e fillet weld rofiles on i e han er standard components.
The inspector observed destructive testing of size l-l/2 (15)
end brackets supplied by Power Piping (O'HS-142).
Thirteen brackets were loaded at an angle in a hydraulic pull test device at the Pacific Test Laboratory at WNP-1/4.
The fillet welds varied in appearance and included sizes of 3/16" and 1/4".
All tested brackets failed at well above the design load of 3 kips.
Only one failed at less than the proof load designated in ASNE Section III-NF (13.9 kips proof load versus 13.6 kips failure load).
Test results are currently being evaluated by Burns and Roe.
Required weld size data has not yet been provided by the manufacturer.
12.
~lleetin s
The inspector discussed his inspection findings with the WPPSS site gA manager on October 10, 17, 24 and 31, 1980.