IR 05000397/1980019
| ML17275A855 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/27/1981 |
| From: | Dangelo A, Dodds R, Haist D, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17275A854 | List: |
| References | |
| 50-397-80-19, NUDOCS 8103050741 | |
| Download: ML17275A855 (18) | |
Text
U.
S.
VsUCLEAR REGsv'LKTORY CO~~1ISS ION OFFICE OF INSPECTIOV AND ENFORCEMENT
REGION V
Report No.
50-397/80-19 Docket No.
50-397/80-19 License No.
CPPR-93 Sazeguards Group Licensee:
Washington Public Power Supply System P.
0.
Box 968 Richland, Washington 99352 Faci] ity Name Washington Nuclear Project No.
2 (WNP-2)
WNP-2 Site, Benton County, Washington Inspection conducted:
. NOVember 4 7
"/
Inspectors:
i j-. -/flJP)
D.
P. artist, Reactor Inspector
'~ J.
Wagner, Reactor Inspector
.~'./.>i~z, A. J/
D'A gelo, Reactor Inspector Approved Sy: ~'~."L.
R. T. Dodds, Chief, Projects Section Reactor Construction and Engineering Support Branch Sunmtary:
rlz;.hg IDate Signed l/A~1 D te Signed il'~:
Date Signed
//~7/Iz Date Signed Ins ection durin the eriod of November 4-7, 1980 Re ort No. 50-397/80-19)
~Al<<d:
1, db d
by d
yb dd P
of construction activities including licensee action on open enforcement items; preparations for repair of deficiencies in the sacrificial shield wall; continuation of investigation of allegations concerning record irregularities by the prime mechanical contractor; and investigation of allegations of irregularities in the construction manager's administration of the quality assurance program.
The inspection involved 75 inspector-hours onsite by three HRC inspectors.
Results:
No items of noncompliance or deviations were identified.
810 s050 Q%
RV Form 219 (2)
h
DETAILS
~
~
1.
Persons Contacted a.
Hashin ton Public Power Su
S stem WPPSS
- H. C. Bibb, Project Manager
- J.
D. Martin, Plant Manager
- G.
K. Afflerback, Deputy Project Manager, Startup
- G. I. Ilells, Deputy Project Manager, Construction
- R. N. Tanner, equality Control Director, Contract 215
- A. M. Sastry, Deputy Project Manager
- B. A. Holmberg, Change Manager
+R. T. Johnson, Project equality Ass@rance Manager
- D. C. Timmins, Engineering Director, Contract.215 R.
M. Foley, Deputy Project Manager, Engineering Burns and Roe.
Inc.
(B8R)
C.
~G.
T. Harper, Site Engineering Manager
- R. D. Carmichael, equality Assurance.
Engineer R.
Powe, Lead Quality Assurance Engineer-Audits
- M. J. Parise, Special Projects Manager R.
C. Root, Site Manager R. Spence, Lead equality Assurance Engineer-Documentation llSH/Boecon/Geri lrlBG S. 'lleihing, Field Melding Engineer
- Denotes those present at management meeting or November 7, 1980.
Additionally, the USHRC Senior Resident Inspector, fir. P.
D. Toth was present at this meeting.
2 ~
Licensee Action on Previousl Identified Enforcement Items a ~
(Closed Noncom liance (50-397/79-10/04)
Failure to Follow Post i<el d Heat Treatment PLJHT Procedures.
rev>ew o recor er charts records were somewhat illegal le) for welds. 1A and 6 had revealed that the heating and cooling rates exceeded procedure and'SME Section III limitations.
The inspector reviewed documentation which indicates that RFll-419-4 weld no.
6 was completed on November 7, 1977; repair weld No. 6RI was completed on November 28, 1977; post weld heat treatment was completed on October 27, 1978.
The PHHT recorder chart was reviewed for conformance with procedure and ASME Section III requirements and found acceptable.
RFll-419-5.7 weld No.
1A will be re-post weld heat treated.
This requirement is documented on Inspection Report Ho. 215-1R-3404.
The inspector had no further questions on the post weld heat treatment of these weld (
-2-b.
0 en Noncom liance 50-397 79-10
Failure to Pro erl ualif Heat Treatment rocedure.
The thermal transient ana ysis per ormed by the licensee to qualify the post weld heat treatment procedure assumed non conservative adiabatic condi tions on the inside of the piping.
The licensee performed finite element two dimensional thermal analyses assuming 6.7 KW and
KW heater blankets and natural convection and forced air flow of 44 ft/sec.
The results of these calculations indicate that the code required minimum soak temperature would be maintained at the root of the weld as shown in the tabulation of results below:
Assum tions Weld Crown Temp.
( F)
Weld Root Temp ( F)
Max.
Temp ( F)
Maximum Minimum Maximum Minimum Under Heater 6.7 KlJ Heater (Case 1)
No air flow 1204 1198 1192 1186 1295 12.0 KW Heater (Case 2)
1209 No air flow 1198 1198 1186 1354
- ~6.7 KW Heater (Case 3)
1203 ir flow approx.
4 ft/sec. 1197 1168 1161 1329 C.
These results indicates that if a 12.0 KW heater (Case 2) were used with no air flow, the maximum temperature under th~ heater would exceed the lower critical temperature (approximately 1330 F) of the material and the ASflE code allowable maximum temperature of 1250 F.
Air flow through the pipe would further increase this maximum temperature.
The effect of these temperatures on the material under the heater blanket will remain open pending licensee evaluation.
(Closed Noncom liance 50-397/80-04/04):
No Formal Procedures lJere Generated to Contr'ol Heat Strai htenin o
the Sacrificial Shield Wall.
0'he licensee identified this item in their report "Engineering Evaluation of the WNP-2 Sacrificial Shield Wall" of August 1, 1980, as concern No. 15.
For brevity, this report will be referred to as the SSW Report.
The report presents evidence that the heat straightening was performed within compliance with the intent of the governing code (AWS D,l.).
The conclusion is that the combination of force and temperature applied during the heat straightening operation was such as not to degrade the material properties.
Therefore the process did not affect the quality of the SSiJ to any significant extent.
The inspector has no further questions on this ite d.
Closed Noncom liance 50-"397 80-04 06; Procedures for Weld Se uence and Distortion Control Were Not Su mitte to t e En ineer.
This is identified as Concern No. 17, Item 2 in the SSW Report.
Licensee evaluation of'he as-built dimensions of the SSW with respect to circularity and vertical plumb were found acceptable.
This evaluation was performed at the 541'-5" elevation.
The reports also states that the lack of cracks due to residual stresses which could result from an inproper weld sequence provides confidence that a problem with high reaction stresses does not exit.
The inspector has no further questions.
3.
Licensee Action on Previous Ins ection Findin s
a
~
Closed)
Unresolved Item (50-397/80-04/03
'o'Formal., Procedures for Cold Bendina of Curved Plates in the Sacrificial.Shield Wal b.
This is identified in the SSW Report. as concern No. 6.
The major concerns in cold bending the steel plates, are the possibilities of degradation of mechanical properties and/or brittle fracture occuring during the bending operation if the metal temperature is too low, In addressing these concerns, the SSW Report states that for the low strains used in the SSW the effect on strength and ductility is not significant.
Also, at these strain levels, there is no significant probability of creating cracks by cold bending.
The effect of cold bending on the nil-ductility.transition temperature (NDT) of the A36 SSW plates, is being determined by the licensee.
Although the final test report was not available during this inspection the licensee stated that the resultant shift in NDT of the as-bent plate versus the as-received plate is within acceptable limits.
These test resul.ts will.be presented in an addendum to the SSM Report.
The inspector.has no further questions on this item.
(0 en Followu Item (50-397/80-10/04)
- Prom t, Re ortin of Potential 50.55 e
Construction Deficiencies An NRC inspector had identified a potential 50.55 e
construction deficiency regarding motor control center mounting base welds.
This specific deficiency was determined not to be reportable as described in IE Inspection Report No. 50-397/80-14.
The issue of prompt reporting, however remained open.
The inspection verified that direction has been, received from the licensee's corporate quality assurance department regarding the reporting of potential 50.55(e) construction deficiencies.
This direction is to be implemented by a project procedure which is now under development.
This procedure will be examined during a subsequent inspectio Q l~
4.
Alle ation of Record Falsification a.
Review of ualit Records An allegation had been made that WBG pipe and hanger guality Records were falsified ( IE Inspection Report No. 50-397/80-08).
An additional
pipe (juality Records of the 1979 photocopied records were compared with the original.
In each case, records where information had been added or changed had been initialed and dated as required by the contractor's procedure No.
WP153,
"Changes to guality Related Records/Documentation".
The inspector will examine a larger sample duri ng subsequent inspection.
(50-397/80-19/Ol}.
5.
Alle ations of Im ro er ualit 'Assurance Practices 'b the Construction Mana ement Or anization.
a
~
Statement of Allegations On October 9, 1980 the inspector met with an individual and received nine (9) specific allegations concerning the quality assurance practices of ihe construction management organization, Burns and Roe, Inc. during'the time period of 1975 through 1977.
The specific allegations as understood by the NRC are. as follows:
(1)
Audit findin s were removed b.
the qualit, assurance mana er.
An audit was conducted by the quality assurance organization which resulted in sixteen (16) audit findings.
Later, some of the findings were removed by the qual.i,ty assurance manager.
It was not known whether or not the findings removed. were ever resolved.
(2)
Nonconformance re orts and corrective action re uests were voided b
the ualit assurance mana er.
Documented deficiencies were voided, by the qualilty assurance manager without explanation.
It was not known whether or not the deficiencies were ever resolved.
(3)
A corrective action re uest was im ro erl closed A corrective action request was issued against a contracto'r but the stated deficiency was never acknowledged by the contractor.
The corrective action request was later accepted'by the construction manager's quality assurance organization.
(4)
Work ma not have been sto ed as re uired 'b 'alit assurance rocedures.
A corrective action request against a contractor was elevated from category 'C'o category 'D'hich requires that work be stopped until the corrective action request is resolved.
The alleger does not believe that work was ever stoppe (5)
The Burns and Roe ual it assurance mater ial control rou was erformin recei t'ins ection or site contractors wit out written rocedures.
At the time that pre-purchased equipment was being received, the contractors, who were responsible for receiving inspection, did not have the appropriate drawings or purchase order requirements to enable them to perform receiving inspections.
Equipment was checked for overage, shortage, and damage, and conditionally released.
Eventually, the BER quality assurance group started performing receiving inspection without a procedure and documenting them on an inspection report.
B&R later performed receiving inspections to a contractor's procedure No.
206 (6)
The main steam sto valves'were instal:led,;in'the wron location.
There were problems with equipment identification and as a
result, the main steam stop valves were installed in the wrong place.
This was later identified, and.corrected.
(7)
A contractor's nondestructive examination. procedure was inadeauate.
Procedure No. (CP-6 for visual weld examination did not require a record of the depth or location, of excavati,on for weld repairs.
(8)
Audits b MPPSS did noi em hasize corrective action b
Contractors.
Audits 'by the licensee focused on the construction manager'
surveillance program when deficiencies were identified instead of focusing on the contractor's performance.
(9)
Se aration of"electrical cables fr'om instrument.,tubin
'on re undant s
stems is not'bein consi ere
.
Additionally, the individual provided general,. al.legati,ons of deficiencies in the areas of the adequacy of the owner's quality assurance program, and the construction manager'
quality assurance program.
These additional allegations will be investigated duri ng a subsequent inspection.
(50-397/80-19/02)
An investigation of the specific allegations was initiated by reviewing the quality assurance procedure requirements applicable at the time of the alleged deficiencies.;, reviewing records of the alleged deficiencies; and interviewing individuals associated with the records and activities.
A total of -five individuals were interviewed during this initial investigation.
I)any of the individuals who would have been involved in the areas of alleged deficiencies are no longer employed at the sit il
aJ
- I
b.
Investi ation Findin s
Audit findin s were removed b
the ualit assurance mana er Finding:
The allegation was partially substantiated.
The original audit package for audit No. 76-13, conducted on the 215 contractor during the time period of December 14-17, 1976 contains an apparent discrepancy between the initial audit findings and the final audit findings.
The internal review of audit findings for presentation to the contractor indicated a total of 16 findings on December 22, 1976 as did the post audit meeting minutes on January 6,
1977.
The audit summary report, issued on February 3, 1977 states a total of 15 audit findings.
The audit checklist identified 16 audit findings.
Each of the first fifteen of these findings was transferred to an audit finding report.
Finding No. 16, that. the contractor had no materials handling superintendent, was not transferred to an audit finding report for concurrence and resolution by the contractor.
(2)
guality assurance procedure No. 2808-(-4.7, Revision 4, "Site Contractor Audits", paragraph 6.6, requires the qual.i ty assurance engineer io note any finding not in compliance with applicable procedures, codes, eic.
on an audit finding. report form.
Paragraph 6.7 requires the quality assurance engineer to formalize his finding upon completion of the audit.
The failure to formalize audit finding No.
16 appears to be substantiated.
The involvement of the quality assurance manager has not been substantiated at this time.
The inspectors will attempt to contact the quality assurance engineer involved during the continuation of this investigati.on.
This item is considered unresolved (50-397/80-19/03).
Nonconformance re orts and corrective action re uests were voided b
the ualit 'assurance mana er.
Finding:
The allegation was partially substantiated.
Inspection Report
No.
1480 dated December 9,,
1976 was issued to document overnight storage of quality class 1 main steam isolation valves in less than the specified level
'8'torage conditions.
Nonconformance report No.
2062 was issued i n conjunction with this inspection finding on December 10, 1976.
On December 16, 1976 this nonconformance report was voided upon the direction of the quality assurance manager.
However, attached to the voided. nonconformance report was an explanatory note which stated that the valves were-adequately covered to meet the Level 'C'torage requirements of the General Electric specifications.
The note also directed that the Inspection Report No.
1480 be reopened as Revision l.
The inspector was unable to ')ocate Inspection Report No. 1480, Revision 1, to verify that this apparent deficiency had been properly resolved.
The licensee is attempting to locate this document.
This item is unresolve Corrective action report No.
1218 dated December 9,
1976 addresses removal of the same quality class valves from the HPPSS warehouse without obtaining owner release for installation.
This corrective action request was voided on December 15, 1976 without explanation and contains the quality assurance manager'
initials.
Inspection Report
No.
R-1479 which is referenced on the nonconformance report was not in the licensee's document vault but a copy was located and found to be voided at the direction of the quality assurance manger.
Quality Assurance Procedure No. 2808-0-1. 13, Revision 7,
"Corrective Action Request" provides no direction on the voiding of corrective action requests, +or does procedure No. 2808-Q-1.25, Revision 3, for control of nonconformances.
.It does not appear that a policy exists concerning the voiding of, quali.ty assurance documents.
The licensee is examining the circumstances of this corrective action request to determine if documentation to support resolution of thi s defici ency exists.
The investigation of voided quality documents will continue and is considered unresolved.
(50-397/80-19/04)
A corrective action request was improperl closed.
Finding:
The allegation was not substantiated.
A Corrective Action,Request No.
1016 was issued to the 215 contractor on April 3, 1975 for placing a hold tag on the RHR pump casing pallet instead of on the piece of equipment itself.
The contractor did not acknowedge the deficiency and provided justification for his position, i.e.
that the pump weighs 14,050 pounds and is bolted to the pallet, and that the quality assurance manual allows the hold tag to be placed on the item or container.
Burns and Roe considered the contractor's response unacceptable and issued Corrective Action Request No.
1016A, dated Hay 2, 1975, reiterating the Burns and Roe interpretation of the quality assurance manual.
The contractor did not acknowledge the deficiency stating that all contractural requirements would be met.
This response was considered satisfactory by Burns and Roe on July 2, 1975.
Quality assurance procedure No. 2808-(-1. 13, Revision 7, paragraph 6.8(2) allows a corrective action request returned with corrective action identified that is acceptable to quality assurance to be dispositioned "satisfactory".
An individual with knowledge of this corrective action request stated that there was a difference of opini'on between Burns and Roe and the contractor which resulted from ambiguous procedures.
The conscious decision to accept the contractor's position was based upon the ambiguity of the procedure and the nature of the deficiency.
The "hold" tag is a multiple copy form so that additional copies were available to document the status of the component.
The inspector had no furthur questions on the resolution of this issu llork ma not have been sto ed as re uired b
ualit assurance Finding:
The allegation was not substantiated.
Corrective Action Request No. 1032-Category
"B" was issued to the 215 contractor on July 22, 1975 to request correction of a deficiency in transmitted documentation.
The contractor acknowledged the deficiency and'agreed to change his quality assurance manual on September 5,
1975 but maintained that the documentation evidenced traceability of the applicable material.
Corrective Action Request No.
1032A was elevated to category 'C'nd issued on September 5,
1975 due to the fact that a contractor reply/action had not been. received by the stated due date of August 8, 1975.
The contractor replied to this elevated corrective action request on October 27, 1975 by essentially restating his response to Corrective Action Request No. 1032.
Burns and Roe considered this response unacceptable and responded with letter No. BRBC-215-F-75-2746 dated November 4, 1975, which elevated the corrective action request to category 'D'nd called attention to Contract. Specfification No. 2808-215, Section 52A, paragraph 3.16,.provisions that
"Failure to take appropriate action to a Corrective Action Request in the time alloted shall require the work to be stopped in the area the Corrective Action Request.applies."
This letter also transmitted the Burns
Roe comments on the contractors reply to Corrective Action Request No.
1032A and, requested a
response by November 17, 1975 without specifically stopping work.
The contractor responded in letter Ho. BCBR-215-75-2033 dated November 26, 1975, restating their position and requesting a
meeting to resolve the differences in opinion.
The inspector was unable to find any minutes of the requested,meeting or any subsequent correspondance relating to resoltuion of this difference in opinion.
equality Assurance Procedure No. 2808-g-l.)3, Revision 7, paragraph nos.
6. 11 and 6. 12 specify form letters to a contractor's Office of the President when response to a
category 'D'etter is unsatisfactory or when response to a form memo is unsatisfactory.
This procedure does not specify an automatic stop work order nor does it address work stoppage and, as such, conflicts with the aforementioned contract specification.
The inspector located a letter No. BRBC-2]5-I=-77-2305 dated August 2, 1977 from Burns and Roe to the contractor which returned Corrective Action Request Nos.
1032 and 1032A accepting the contractor's response and corrective actions and acknowledging that "the technical complexity of the deficiency noted on CAR ]I1032, the confusion which arose over the interpretation of the requirement and the time needed to revise your equality Assurance Program to provide the additional controls, were contributing factors in your failure to comply."
The unresolved issues that remain are:
(1) the discrepancy between the contract specification and Burns and Roe equality Assurance Procedures No. 2808-g-l.'13 regarding the cessation of work when corrective action requests are not resolved; (2) the resolution of the difference of opinion between Burns and Roe and the contractor on Corrective Action Request Nos.
1032 and 1032A; and (3) the action taken or the reasons for inaction during the time period between the contractor's request for a meeting on November 26, 1975 and Burns and Roe acceptance of the contractor's response to Corrective Action
'equest Nos.
1032 and 1032A on August 2, 1977.
(50-397/80-19/05).
(5)
he Burns and Roe ualit'ssurance material 'control 'ou was oerformin recei t ins ection for the contractors without written rocedures Finding:
The allegation was not substantiated during this initial investigation.
Interviews with individuals on this =allegation were inconclusive.
Investigation of this allegation wi'] 1 be continued.
(50-397/80-19/02).
(6)
The main steam stop valves were i'nstal,led. in the wronq locatfon.
Finding:
The allegation was substantiated.
Inspection Report
No. 215-H-77-1031 dated Harch 17, 1977 documents the installation of main steam isolation valve No.
106 in loop 'A'nstead of in loop 'B's required.
A hold tag was initiated and placed on the valve while engineering evaluation was in process.
The actual disposition was to accept the condition.
A nonconformace report was not initiated to document this condition and evidence of an engineering evaluation with concurrence by the vendor, General Electric was not apparent.
These issues remain unresolved.
(50-397/80-19/06).
Specific allegation Nos. 7, 8, and 9 were not substantiated by interviews with individuals.
The investigation of these allegations wi 1 1 continue.
(50-397/80-19/02)
.
6.
Unresolved Items Unresolved items are matters about which more information is required i n order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items identified during the inspection are discussed in paragraph 5.
7.
Hang ement Interview The inspectors met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection.
The items inspected and the observations and findings of the inspectors were discussed.
The licensee acknowledged the investigation findings and will attempt to produce documentation to resolve some of the issue I