IR 05000397/1980022

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IE Insp Rept 50-397/80-22 on 801201-31.No Noncompliance Noted.Major Areas Inspected:Review of Licensee Preparations for Installing Sacrificial Wall Girth Weld
ML17275A859
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 01/26/1981
From: Dodds R, Haust D, Haynes R, Toth A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17275A858 List:
References
50-397-80-22, NUDOCS 8103100036
Download: ML17275A859 (10)


Text

<Report No.

Docket No.

Licensee:

50-397/80-22 50-397 U.

S.

NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION V

License No.

CPPR-93 Hashington Public Power Supply System P.

0.

Box 968 Safeguards Group Facility Name:

Inspection at:

Richland, Hashington 99352 Hashington Nuclear Project No.

2 (HNP-2)

HNP-2 Site, Benton County, Hashington December, 1980 Inspectors:

Inspection conducted:

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T~ th, psident Reactor Inspector r-j uiiP; D.

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g ist, Reactor Inspector i Zd/~/

ate Signed

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T. Dodd', Section Chief, Reactor Construct'ion and Engineering Support Branch Approved by:

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Haynes, Chief, Reactor Projects, Section, Reactor Construction and Engineering Support Branch 5ummary:

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~/</'ate Signed y/z d/I/

Date Signed

'Ins ection on December 1-31, 1980 Re ort No. 50-397/80-22 Areas Inspected:

Routine, unannounced inspection of licensee and contractor activities to re-evaluate and improve detailed work methods.

The inspection involved 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> onsite by the NRC resident inspector, and,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> onsite by a regional based inspector.

Results:

No items of noncompliance or deviations were identified.

!8108 z 00O>>

RV Form 219 (2)

Po

Persons Contacted DETAILS Washin ton Public Power Suppl System A.

M. Sastry, Deputy Project Manager Systems Turnover R. I. Johnson, guality Assurance f<anager T.

A. Gross, Management Systems Task W.

C. Bibb, WNP-2 Project Manager L. J. Garvin, Manager, gA Engineering and Systems Burns and Roe En ineers B&R H. Tuthill, Assistant gA Manager Bechtel Power Cor oration BPC F.

B. Damerval, Reverification Manager Wri ht-Schuchart-Harbor/Boecon Coro./

General Energy Resources, Inc.

WBG M. Houck, Manager-Engineering Other General Contacts and Notes Also, the WPPSS gA 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 also routinely interviewed construction, engineering, and quality control staffs of various site contractor organizations.

Project Personnel During this period the inter-project functions of task III have been transferred to the WPPSS corporate office staff.

The former task III manager announced plans to leave the project at year end.

General A regional office inspector and supervisor were onsite December 2-5, 1980 to assist in review of the licensee's preparations for installing the sacrificial shield wall (SSW) girth weld.

The regional inspector reviewed NRC open items relative to their possible constraint on this work, and examined selected work procedures for compliance with applicable regulatory requirements.

The regional inspector also examined the licensee's master deficiency list for the SSW, to ascertain the scope of that investigation and the licensee's assurance that none of the items identified affect the proposed wor The resident inspector was onsite December 1-5, 8-9, 12, 18-19, and 22-23 this period, During this period, the inspector continued examination of licensee and contractor activities concerning efforts to re-evaluate and improve detailed work methods.

Emphasis was on examination of a Reverification of Completed Safety Related Mork (RCSlJ) evaluation package and related documentation.

The evaluation package for sacrificial shield work by the mechanical contractor had been prepared by the RCSH task force.

This package had been submitted to the 1rJPPSS site gA organization and the MPPSS independent review team for examination and comment prior to beginning work on the sacrificial shield wall girth weld.

The review and resolution of comments have been in-progress during December.

The task II data packages, examined by the inspector were not yet complete, and had not yet been reviewed and resolved by the project quality assurance organization nor the MPPSS corporate independent review group.

The inspectors found that the licensee's independent reviews of the mechanical contractor's work methods and controls for the sacrificial shield wall repairs were not yet complete.

These reviews are to be successfully completed prior to release of the current stop work order on the mechanical contractor concerning installation work on the sacrificial shield wall.

Pro 'ect Status No safety related construction work has recommenced onsite.

However, other construction was restarted during this report period.

Individual work restart authorizations appear to be given close review by the project gA organization to assure that provisions of any stop work orders are not compromised.

(The resident inspector routinely receives copies of such authorizations for information.)

Limited work on the SS~~l, such as layout of reference points, and erection of scaffolds were begun in preparation for restart of the installation work.

Establishment of MPPSS Task Forces The task force functions described in the licensee 17 July 1980 reply to the NRC 10CFR50.54(f) inquiry have been established, but are not fully active.

Reverification of completed work has not been scoped and initiated, although organization provisions have been made and the function recognized.

(Ref.

IE Report No. 50-397/80-18)

Functioninq of llPPSS Task Forces Task force II continues to function as described in the licensee 17 July 1980 reply to NRC 10CFR50. 54(f) inquiry.

Task II activities are still generally confined to review of contractors'evised procedures and preparations for work restart.

Hardware reinspection activities and record reviews have not yet begu Task force III has thus far functioned in an ad-hoc manner.

Several of the specified commitments in the HPPSS reply to the NRC lOCFR50.54(f)

inquiry have been implemented.

However, formal procedures for conduct of Task III activities to meet the objective of applying the lessons learned to other contractor's and other HPPSS nuclear projects have not been provided.

Hith assignment of this objective now to the corporate office, the inter-project coordination possibilities appear to be strengthened.

Other task III activities include HNP-2 contractor management systems evaluations described in paragraph

of this report.

HPPSS Hork Restart Mana ement Control The licensee briefly described elements of the HPPSS project management system for HNP-2, in a letter to NRC dated November 12, 1980.

The inspector reviewed the letter and related site documents and ascertained that the project controls included elements described in the letter to NRC.

In many cases the elements are included in formal Project Management Instructions or similar procedures.

An analysis was not, however, available to identify where each element was formally incorporated into the management controls.

The inspector did not identify any instance where actions contrary to the described elements were being taken.

The mechanical contractor has taken each node on his management system logic network and identified the applicable procedure and paragraph number which prescribe the details in which the controls represented by that node are implemented.

HPPSS site personnel audited four of the nodes to ascertain that the identified procedure references were proper and adequate.

Similarly, HPPSS RCSH personnel have identified essential elements to be included in each contractor'

management system, and are reviewing each contractor's system to assure inclusion of these elements.

Trainin of Personnel The inspector attended a training session held by the mechanical contractor for personnel to be involved in the girth weld work on the SSH.

The subject of the session was work procedure HP-170, the process control procedure for the work.

Lesson plans had been developed, instruction was well planned, key personnel were in attendance, and a reasonable examination was given to attendees to probe for weaknesses.

The session was attended and audi ted by a representative of the licensee site gA organi zation.

Attendees were not given copies of the procedure prior to attendance of the training session and no HBG company instructions provided guidance for assuring advance reading of complex procedures were required.

This appears to undermine the training effectiveness and will be the subject of further inspection.

(50-397/80-22/01)

9.

Licensee Action on Previous Ins ection Findin s a ~

Closed Noncom liance 50-397 79-16-08

Failure to maintain cleanliness of instrument sensin lines.

Cl osed Noncom 1 iance 50-397 79-16-06:

Fai1ur e to masnta~n cleanliness of instrument rack/tubin

.

b.

The inspector examined records substantiating the statements in HPPSS letters to NRC dated February 4 and 29, 1980.

These records included corrective action request Nos.

1425 and 1424, MPPSS letter No.

HNP 2FL-218F-80-794 to Fischbach 8 Lord, a

Johnson Controls Project Manager directive to construction supervisors and foremen, training session attendance sheets, and penetration inspection records for October/December 1980.

These records demonstrated management emphasis on cleanliness and protection of instruments and tubing.

Minutes of a meeting held on March 6, 1980 noted attendance of personnel from Johnson Controls and Fischbach/Lord wherein the llPPSS Construction guality Manager emphasized instrument rack cleanliness control.

Memorandum No.

$1LB-gA-80-86 indicated increased emphasis by site gA personnel on surveillance of instrument rack cleanness in March 1980.

November 12-17, 1980 site gA reports document results of,walkdown inspections of instrument racks for cleanliness and instrument/tubing caps.

The NRC inspector briefly accompanied the licensee staff on part of this inspection.

An NRC regional inspector examined MPPSS startup organization procedures to ascertain controls to recap/protect instrument/tubing/racks following access to racks for startup related work.

The issue appears to be resolved at this time.

0 en Followu Item 50-397/80-10/04) - Prom t Reportin 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 construction deficiency was determined not to be reportable as described in IE inspection report No. 50-397/80-14.

The inspector examined a startup problem report No.

I345 dated May 2, 1979 which states that flow transmitters feeding the signal to flow switches which isolate the main steam leakage control system upon high leakage flow do not have sufficient range to activate the flow switches.

This deficiency was received by the quality assurance group on June 13, 1979 and by the regulatory review committee on July 23, 1980.

Both reviews concluded 'that the deficiency was not reportable because'"The preoperational tests are conducted prior to initial startup for the purpose of detecting problems of this nature.

Therefore, this condition would not have gone undetecte The inspector reviewed with the licensee the applicable portion of the NRC guidance issued April j., 1980 which states:

"The fact that a deficiency is obvious and could not possibly go undetected and therefore could not adversely affect safe operation does not negate the requirement to formally report the deficiency if it meets the criteria of 50. 55(e)."

The licensee stated that they will review this item again for reportability as a potential 50. 55(e) item.

This will be examined during a subsequent inspection.

10.

Flammabilit Resistance of Sacrificial Shield Wall Shield Material The inspector reviewed information submitted by the licensee responding to the NRC concern over the flammability resistance of the shielding material to be used in the repair of gaps in the sacrificial shield wal l.

The testing performed on ihe high density polymer or its equivalent included ASTM-Ell9-73 (NFPA-251), "Standard for Fire Tests of Building Construction and Materials"; ASTM-E-84-79a, "Standard Method of Test for Surface Burning Characteristicts of Building Materials";

and a mockup test to qualify the shield material with respect to heat input during welding.

Test results indicate that penetration seals of the shield material remained in place for the 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> duration of the fire exposure test and prevented the passage of flame (E-119-73);

flame spread rate and fuel contribution were 10 and 5, respectively as a ratio with asbestos-cement board 0 and red oak flooring 100 (E-84-79a);

and no deleterious effects from heat input during the welding of the mockup test.

The inspector had no further questions on the suitability of this mater ial for the intended application.

11.

Sacrificial Shield ilail Master Deficienc List The inspector examined the contract 215 sacrificial shield wall restart task No.

3 program and results to ascertain whether or not deficiencies which may affect the partial penetration weld repair at elevation 541'-5" have been identified and resolved.

Task No.

has determined that as of October 29, 1980 all sacrificial shield wall master deficiency list and document discrepancy notice deficiencies requiring disposition prior to restart on the partial penetration weld were documented on nonconformance reports and dispositioned through engineering signoff.

The inspector had no further questions at this tim.

Review of Qual it Assurance Im lementin Pr ocedures The inspector reviewed the following procedures prepared by the 215 Contractor for use on the partial penetration weld repair at elevation 541'-5".

Procedure No.

Title QAP-360 Quality Assurance Deficiency Reports IIP-170 Sacrificial Shield Mall Girth Held The inspector noted that MP-170, paragraph 4.14.1(d) specifies that

"Discontinuities over 1 inch (25.4 mm) in length with depth greater than 1 inch shall not be cause for rejection of the plate.

Removal of laminations shall not exceed 1 inch in depth and be sealed off and welded out to joint surface."

This requirement does not agree with the controlling AlJS D. l. 1 structural welding code requirement (paragraph 3. 2. 3. 2) to determine the 'size and shape of discontinuities over 1-inch in length and depth by ultrasonic examination as a

basis for dispositioning them.

This deviation is documented as project engineering directive No. 215-3830 and was submitted to the NRC Office of Nuclear Reactor Regulation for approval as a part of the partial penetration repair weld at elevation 541'-5".

The inspector had no further questions on this issue.

13.

Hang ement Heetin s

The inspector met with the LJPPSS site quality assurance manager approximately weekly to discuss status of inspection efforts and to receive a status report of principal hlPPSS activities.

Also, the inspector met with MPPSS and BAR site management personnel in conjunction with NRC regional personnel on December 5,

1980.

The inspectors summarized-the scope and results of the inspection activities documented in this report.

Hr.

R.

G. Hatlock, llNP-2 Program Director, represented the licensee senior project managemen e P