IR 05000397/1981006
| ML17275B056 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/27/1981 |
| From: | Dodds R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17275B055 | List: |
| References | |
| 50-397-81-06, 50-397-81-6, NUDOCS 8106080100 | |
| Download: ML17275B056 (19) | |
Text
eport No.
50-397/81-06 U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION V
Docket No.
50-397 License No.
CPPR-93 Safeguards Group Licensee:
Washington Public'ower Supply System P. 0.
Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project No.
(WNP-2)
Inspection at:
WNP-2 Site, Benton Count
, Washington Inspection conducted; March 1-31, 1981 Inspectors:
t
,
d'or esl ent nspector-27-8'/
Date Signed Date Signed t
proved By:,/ Zsv'y R. T.
odds, hief React r Proj cts Section h'2 Date Signed Al-I'ate Signed Summary:
Ins ection on March 1-31, 1981, Re ort No. 50-397/81-06 A~I: i, di p
i 11i d
contractor activities to re-evalute and improve detailed work methods.
The inspection involved 83 inspector hours on-site by the NRC resident inspector.
Results:
No items of noncompliance or deviations were identified.
~
neo@0 RV Form 219 (2)
C
DETAILS 1.
Persons Contacted Washin W.
- R
- B G.
A.
- W.
- M.
J.
- J A.
D.
ton Public Power Su
S stem WPPSS)
C. Bibb, Project Manager T. Johnson, Project guality Assurance Manager A. Holmberg, Deputy Project Manager, Engineering I. Wells, Deputy Project Manager, Construction H. Sastry, Deputy Project Manager, Systems Turnover G. Keltner, Assistant Construction Manager A. Clinton, Project Management Specialist, Systems Turnover Maidment, Project Manager's Staff Thorpe, guality Assurance Engineer N. Kugler, Supervisor, Design Engineering C. Timmons, Director, Contract 215 Engineering Burns and Roe, Inc.
BSR)
H.
R.
R.
E.
L. E.
L. F.
Tuthill, Assistant guality Assurance Manager Carmichael, Supervisor guality Assurance Surveillance Pokos, General Superintendent Akers,'enior Supervisor, Welding Wri ht-Schuchart-Harbor/Boecon Cor./General Ener Resources Inc.
WBG)
P. Garcia, Project Manager S.
Y. Young, Corporate Audit Manager K. Bishop, Engineering Manager D.
W. Tolly, Deputy Project Manager, Containment Area Bechtel Power Cor oration D. Johnson, guality Control Manager
- Denotes personnel present at monthly summary management meeting.
Also, the WPPSS gA Manager met weekly with the resident inspector to discuss status of licensee activities and NRC findings.
In addition to the persons identified above, the inspector also routinely interviewed con-struction, engineering, and quality assurance staffs of the licensee, architect-engineer, and the contractor on-site organization Pro ect Personnel The Burns 5 Roe Site engineering manager, Mr. G. Harper, has been reassigned; Mr. A. I. Cygelman has been assigned the position of Site Engineering Manager.
During this period, the WBG Project General Manager announced that he would be assuming the duties of Construction Manager.
General The resident inspector was on-site March 2-6, 9-13, 19-20, 23-27, and 30-31, 1981.
During this period, the inspector continued examination of daily activities of the licensee, the architect-engineer, and the mechanical contractor concerning efforts to re-evaluate and improve detailed work methods.
Attendance at meetings, examination of correspondence, and interview of personnel at all organizational levels was involved.
The inspector sought to as-certain the scope, criteria, personnel, data base, conclusions, and corrective actions involved in the implementation of the com-mitments in the WPPSS July 17, 1980, reply to the NRC 10 CFR 50.54(f) inquiry.
Four NRC region V inspectors were on-site March 2-6 to review activi-ties of the electrical contractor, relative to restart of material receiving inspection.
They also reviewed mechanical contractor weld records, and status of certain previously identified NRC findings.
An NRC Region V inspector was on-site March 9-13 to review activities of the containment design retrofit contractor, relative to restart of work for weld pad installations.
An NRC Region V inspector was on-site March 23-25 to review status of work on the sacrificial shield wall girth-weld.
Results of the above inspections are documented in separate inspec-tion report Bechtel Transition Activities During this period it was announced by WPPSS that Bechtel would assume the function of Construction Manager for the WNP-2 project.
This is to include equality Assurance.
The licensee would perform a equality Assurance overview function.
Generally, the integrated WPPSS/BSR or-ganization would be abolished.
Burns
& Roe would retain the engineering function as plant architect engineer.
Bechtel is functioning as Systems Completion Contractor at this time.
The licensee considers Bechtel as one more contractor under the existing quality assurance program, relative to this activity.
f
-3-On March 4, 1981, the inspector interviewed the Bechtel guality Control Manager, WNP-2 and 1/4 Projects, and attended an orientation and train-ing session given to Bechtel quality control personnel.
In addition to Bechtel ANSI-N45.2.6 level II inspectors, several personnel from the local union'all have been hired by Bechtel, including personnel who have previously.and recently worked at the WNP-2 site.
These personnel were engaged in a series of training sessions, including physical demonstra-tions of their ability to identify nonconforming conditions.
Functionin Of The WPPSS Task Forces Task Force II continues to function as described in the licensee's July 17, 1980, reply to the NRC 10 CFR50.54(f) inquiry.
Task Force II activi-ties are still confined to reviews to assure that contractor work methods are adequate for assuring compliance with conditions of the construction permit.
Hardware reinspection activities and record reviews have not yet started, nor have approved plans yet been established.
Some planning activities are underway.
Since most of the site contractors have been released to restart work at the end of March, the size of the task force has been reduced to a current level of twenty professional and clerical personnel.
Training for phase-2 reverification work had not been started.
Task Force III activities involve review and strengthening of management systems, including those of the contractors.
Additional emphasis has been given to this area this month.
Contractors have been required to develop management system flow charts, which are evaluated and audited as part of work restart reviews by WPPSS.
Additional details are des-cribed in the WPPSS bi-monthly report dated March 12, 1981, (G02-8156).
The inspector verified implementation of the activities described therein.
Limited Work Restart Authorizations The inspector examined work restart authorizations issued to the site contractors in March.
For each such authorization the inspector verified that it was reviewed by the project quality assurance organization, and the RCSW as appropriate.
The inspector ascertained that the particular work released was commensurate with the status of the WPPSS evaluations of detailed work methods and corrective action, plans, as described in the WPPSS July 17, 1980, reply to the NRC 10 CFR 50.54(f) inquiry.
The following work release items were examined:
a.
Electrical Contractor (218)
training of personnel b.
HVAC Contractor (216) - conditional release for all work c.
Containment Retrofit Contractor (213A) - fabrication of hangers d.
Containment Retrofit Contractor (213A) - conditional release for all work
e.
Mechanical Contractor (215) - limited corrective action on "26 Borg-Warner valves to stake stem nuts to correct conditions such as described in IE Cir culars 79-04 and 80-04 f.
Mechanical Contractor (215) - issuance of purchase orders Commitment Control Im rovements The licensee has assigned an individual responsibility to monitor status of the various stop work orders issued to the contractors, and the related conditional release items, to ascertain that the conditions are met by the scheduled dates.
The licensee has established a system whereby findings presented by the NRC inspectors at exit meetings are assigned to individuals for action.
This includes questions and findings presented by the Resident Inspector at weekly exit meetings.
A Corrective Action Request SCAR-1490 was pre-pared by WPPSS, identifying the failure to implement certain commitments made to NRC in the past.
Corrective actions are still under development relative to this matter.
The licensee has assigned personnel to list and evaluate status of imple-mentation of commitments made to NRC relative to the WPPSS July 17, 1980, reply to the NRC10 CFR 50.54(f) inquiry.
The inspector has noted WPPSS efforts to address some of the deficiencies in implementation, as identified in recent NRC inspection reports.
The licensee advised the inspector that it is now planned that construction craft personnel will be trained by their supervisors at toolbox type sessions, rather than by a formal training depart-ment.
Also, the craft personnel would not be subjected to testing, except for welding, NDE, or quality control, as called for by codes and standards.
The licensee noted that this was a change from the position described in the WPPSS
"Management Systems Description" submitted to NRC on November 12, 1980.
The licensee is evaluating the need for WPPSS clarification of the public record in this regard.
Falsification of ualit Control Ins ector Resume The mechanical contractor reports that his supervisor interviewed an individual who had been dispatched from the local b'598 of the Plumbers and Steamfitters Union (which represents quality control inspectors for several contractors at the Hanford reservation).
The individual was given the required screening examination, and passed it acceptably and was hired.
Subsequently, the contractor found that the individual had falsified her resume to show inspection experience, where in fact she had little or none.
The contractor terminated the employee and notified the union hal The containment retrofit contractor identified a quality control inspector who had presented inaccurate information on his resume.
The contractor elected to not reinspect work performed by this inspector, based upon the fact that all work performed in the past under this contract (213A) has already been re-evaluated/re-inspected over the period June 1980 to March 1981 (reference PDMWNP2-213A-CM-81-107).
The project managers for the contractors also indicate that they are attempting to obtain better cooperation from the union in providing resumes for dispatched inspectors, with the potential for improved verification of education/experience.
With several large nuclear construction projects in this area (including Department of Energy facilities at the Hanford Works), the demand for inspectors is expected to increase significantly in the 1981-1982 period.
The need to be cognizant of the potential for weakness in this area was discussed with licensee management.
Sacrificial Shield Wall Girth Weld Re air - Document Control The inspector observed work in progress, interviewed -personnel and examined contents of the work package JP-135 (yellow binder) for weld joint preparation work in progress.
The inspector considered the provisions of Work Procedure WP-86 Revision 12 "Work Package Control", and particularly paragraph 3.2.5.a, which requires separa-tion of documents into two packages, red and yellow, with the yellow binder containing the material necessary for performance of work, and the red binder as the permanent file for complete documentation.
The inspector found PED-215-W-4959 in the yellow work package at the work area.
Also included was PED-215-W-A079, which voids PED-215-W-4959, and includes technical instructions which conflict with 84959.
There also were two copies of work procedure WP-170 Revision
"Sacrificial Shield Wall Girth Weld" in the work area; technical instructions of paragraph 4.7 are amended by the PED's 5'4959 and PA079.
The two copies of the procedure were marked "Information Only" and paragraph 4.7.was not marked as being affected by the new PED's.
The inspector queried responsible weld engineers and a quality control inspector at the work area, and was not convinced that use of outdated documents was precluded.
Therefore, document control in work areas will be examined during a future inspection.
(397/81-06-01)
Pi e Whi Restraint Boltin Control The inspector reviewed documentation and interviewed personnel regarding corrective actions for a previous situation where wrong sized bolts and been issued to construction forces.
Documents PEM-044, SSWO-FJB-1097, and in-process inventory lists supported WBG pipefitter and field engineer statements.
These show each bolt at the containment building storeroom has been checked against a listing of required length, diameter and grade for the particular support to which it corresponds.
For supports which have not yet been removed from their installed locations (for repairs),
the supports have been identified for later verii'ication following remova Removal of the supports has been classified by the licensee as a
non-quality related activity, and is being controlled under procedures approved for quality class II work only, such.as WP-330.
Mechanical Contractor Orientation and Documentation The inspector observed a two hour orientation session conducted by the mechanical contractor on the evening of March 26, 1981.
About 100 managers in vairous disciplines and at all levels attended this point-by-point review of Appendix B of 10 CFR 50.
The WBG Project General Manager, guality Assurance Manager, and guality Assurance Audit Manager chaired the session, with detailed presentations by the Audit Manager.
The presentations were thorough in emphasizing quality assurance requirements.
The WBG Project General Manager has also issued an indoctt ination
"Reading File" which is provided to each new employee, including crafts.
This four page document alerts the new employee to the quality related factors which have been a problem in the past.
It cautions regarding following procedures, bypassing tags and hold points, material traceability, engineering change control, work package control, and other items.
The inspector identified no items contrary to NRC regulations or safety analysis report commitments in this WBG effort.
Pro ect Com liance With Re ulator Guide 1.58 Revision 1 The inspector examined a
WPPSS SAR change Notice (SCN-80-327) which is dated December l2, 1980, and designated for incorporation into FSAR Amendment 13, Appendix C3-(RG-1.58).
This change commits to Revision
of RG-1.58, via an alternate approach, as of November 1980.
The only exception to RG-1.58 noted, are the provisions for formal certifications of personnel.
WPPSS has not directly imposed RG-1.58 (or referenced ANSI-N45.2.6-1978)
on its contractors, but rather has incorporated detailed implementing requirements into the job specifications for each contractor.
This had left areas of RG-1.58 for which the implementation and.compliance are not readily apparent, and where the procedure review staff has raised questions.
Accordingly, the inspector requested the licensee to identity those specific areas where RG-1.58 requirements have not been fully invoked.
The following are the results of that review.
The inspector concluded that the commitment has been sufficiently implemented by directions to the contractor.
a.
RG-3..58 paragraph 2.a imposes SNT-TC-1A-1975, whereas WPPSS instructions to site contractors had allowed use of SNT-TC-1A-1968.
The RCSW review of the sacrificial shield wall girth weld repair (checklist 215-C.g.'d-08)
used the
.1968 edition for the WBG procedure WP-,157.
By memo dated January 27, 1981, the WPPSS guality Assurance group affirmed that all
b.
C.
contractors except WBG had adopted the 1975 edition; it requested that WBG specifications be modified to require commensurate compli-ance by WBG.
WPPSS RSCW task force memorandum dated December 31, 1980, (RCSW-80-302) identifies that WBG NDE level III personnel have been evaluated in accordance with the 1975 edition paragraph 5.5.4, which allows waiver of examination.
The inspector considered that the commitment to SNT-TC-1A-1975 has been implemented.
RG-1.58, paragraph 3, requires that ANSI-45.2.6 be used in conjunc-tion with ASME Sections III/XI. The licensee has required on-site contractors to comply with this, but has not required on-site contrac-tors to impose this requirement on their subcontractors or suppliers.
WPPSS has determined (QA2-80-471 dated Novembe~ 17, 1980) that pro-curement of ASME hardware is essentially complete, except for materials, and that imposition of requirements beyond basic ASME requirements is not of concern.
The inspector noted that, with all complex ASME equipment installed, the intent of the RG-1.58 'appears to be satisfied.
ANSI-N45.2.6, paragraph 2.3, requires re-evaluation of personnel at 3-,year intervals.
The WPPSS instructions to contractors requires only that contractor programs assure that suitable proficiency be acheived, maintained and corrective actions be identified f'r proficiency failures.
However, WPPSS has identified in QA2-80-471, dated November 17, 1980, that periodic/annual appraisals for merit increases be conducted by all site contractors.
Also, the project schedule calls for contractor work completion before a 3-year period would expire.
The inspector considered that the intent of the stand-ard has been met.
d.
ANSI-N45.2.6, paragraph 2-4, requires certification of personnel in writing; paragraph 3 refers to levels of capabilities.
The WPPSS instructions to contractors require procedures to document QA/QC personnel working knowledge, on-the-job training, and results of examinations.
The instructions require training to the procedures governing the inspection activities, and examinations against such procedures.
The instructions specify levels of capability as
"Inspector, QA Engineer/Lead QC Inspector, Senior QAE/QA/QC Supervisor",
with education/experience requirements commensurate with levels I,II,IIIof the standard.
The inspector considered that the intent of the standard has been met.
13.
Licensee Action On Previous NRC Ins ection Findin s
The WPPSS Quality Assurance organization has assigned three individuals with full time duties for followup on previous and current inspection findings.
These individuals have prioritized the backlog of issues and are addressing each one with the responsible contractors.
For each item, the Quality Assurance engineer prepares a checklist for evaluation of the contractors'orrective action scope, actions to preclude recurrence, and detailed verification checkpoints.
After verification of implementation
of the corrective actions, the guality Assurance engineer compiles supporting data and maintains the material for review by the NRC inspector.
The system appears to be showing some result in reducing backlogs.
Closed Followu Item 397/79-14-01
As updated in report number 80-04, mechanical contractor procedure gCP-22 was noted to omit ANSI-N45.2.6 requirements in the area of prerequisite experience/education for inspection personnel.
This procedure was re-written as WP-157, to comply with WPPSS direction issued in PED-215-4211.
The new pro-cedure addresses education/experience commensurate with the ANSI-N45.2.6-1978.
The inspector noted various WBG efforts to obtain personnel meeting the specified requirements,,
and WBG efforts to obtain corrective actions (e.g.
memo 8PGM-1437 dated January 21, 1981) where the local union has dispatched quality control personnel who could not pass the WBG written entrance examination.
The WBG Project General Manager has been personally involved in attempts to improve this situation.
The inspector considered this matter to adequately addressed by the contractor.
Closed Unresolved Item 397/80-08-03
CFR 50.55(e) report involving acceptance criteria and evaluation of sway brace end-brackets.
Status of this item was previously reported in NRC inspec-tion reports 80-17 and 80-18.
The responsible engineer has identified Power Piping Company end brackets received in sizes 815, 25, 40,
and 80.
Additional brackets from Nuclear Piping Services (NPS) were also identified in sizes 815, 20, and 25.
The brackets originally reported by WPPSS as originating from ITT Grinell had been mis-iden-tified by the engineer, and were identified as being from NPS.
The NPS bracket sizes 815 and 820 were pull tested with moment-tension loads, and were found to meet proof-loads specified in ASME Code Section III - NF.
Testing of size 825 is also planned.
The Power Piping Company bracket sizes 815, 825 and 840 were tested with straight and moment loads.
The size 5'15 passed all proof loads.
The sizes 525 and 0'40 involved several failures under moment loads.
The size b'40 also experienced failures below proof loads during straight pull tests.
Sizes 850 and 880 were not pull tested due to their size and limited numbers, (e.g.
one 880).
The engineer has identified each location where such brackets are called for by design.
The engineer has derated the Power Piping brackets based on the test results.
Of about 800 brackets called for by design, 480 ordered involve welded construction; of these 16 require corrective action as a result of the derating.
For sizes 550 and 480, the engineer plans to refabricate these to assure adequate weld siz As a separate open item, this matter is considered closed.
Subsequent inspection will be made in connection with issuance of the final 50.55(e)
report by the licensee.
Closed Followu Item 397/80-08-04):
Mechanical contractor (WBG) docu-mentation of inspection findings.
The contractor has issued procedure QAP-360 to supercede procedures WP-150 and QAP-5 for the issuance/handling of inspect'ion reports ( IRs),nonconformance reports (NRCs),
and corrective action reports (CARs).
The procedure provides prenumbered IR and CAR forms, appropriate logs, and assignment of blocks of prenumbered forms to required individuals.
The procedure calls for filing of voided or cancelled IRs and CARs, and documentation of owner approval of any voided NCR.
The'rocedure still requires quality assurance engineer validation of each IR, and return of voided IRs to the initiator.
The identification of voided IRs is maintained via the log of pre-serialized numbers and daily logging of each IR written.
Maintenance of file copies of non-validated IRs is not specifically required in the procedure, but is implied by paragraph 4. 1.2 reference to filing cancelled (preserialized)
IRs.
The WBG Quality Assurance Engineering Supervisor stated that the next revision of WP-360 would clarify the requirement to file non-validated IRs, but in the interim he considered that one-to-one filing for the pre-serialized IRs would be maintained.
WBG internal audit 881-1 was conducted January 28, 1981, and identified that provisions of procedure WP-360 were not being complied with in several respects, including failure to issue blocks of pre-serialized numbers and failure of the Quality Assurance Systems Supervisor to perform daily update of the Master IR Log.
Corrective actions have been identified and accepted and verified by the auditors on March 11, 1981.
WPPSS quality assurance surveillence on March 6 verified that inspection reports are now pre-serialized and that voided IRs are being filed.
The inspector considered that the audit-ability of the validation/voiding aspects has been established.
A Closed Unresolved Item 397 80-08-06
Engineering review of weld joints requiring more than two repairs.
The mechanical contractor (WBG)
requested engineering clarification of specification restrictions on multiple weld repairs; this was submitted via RFI-215-7076-xx-17.
Engineering responded that cut-out of a weld is not considered to be a
repair.
Engineering also issued a specification change (PED-215-W-4872)
which directs that specification sections 17A, 17C and 17D be clarified accordingly.
Additionally, the RFI reply specified approval of the engineer prior to reworking cut-outs.
This was subsequently revised to delete this hold point.
The contractor issued procedures GWS-1 revision 3 and GWS-2 revision 6 which require notification of the engineer prior to perfoming the cut-out.
The procedures paragraphs 4.8 and 4.9 establish administrative controls and documentation for cut-out Closed Followu Item 397 80-08-10
Form NF-286 contains a note w ic states that t e temporary welding record will not necessarily form a part of permanent documentation.
The contractor has prepared procedure GWS-1 revision 3 (for structural steel welds)
and GWS-2 revision 6 (for piping and hanger welds), which supercede procedure WP-42.
These procedures specifically require retention of the new temporary attachment control form NF-286A in the work package, after completion of removal of the attachment.
The licensee guality Assurance staff verified that the procedures have been clarified, as described here, and verified that contractor personnel have been trained to the new procedures.
The licensee did not identify a means to ascertain if previous controls resulted in some Forms NF-286 being omitted from permanent files.
The contractor evaluated the question of WP-42 paragraph 2.9.1.3 inference that NDE may not be performed on all temporary attachment welds.
Contract specification section 17D addresses welding temporary attachments to structural steel, and does not require NDE examination upon removal.
This is consistent with AWS-Dl. 1 requirements.
The new procedures GWS-1 and GWS-2 clearly require NDE to be assigned by the welding engineer on Form NF-.6A for piping.
Closed Followu Item 397/80-17-01
Task force personnel qualifi-cations.
Potential conflicts of interest and qualifications of RCSW Task Force personnel were considered by WPPSS in the January 1981
"Resolutions to Independent Review Team Comment to SSW Girth Weld Repair Package".
Documents RCSW-80-144 and 80-262 (standard form letters compiled for each team member)
addressed potential conflicts of interest.
Procedure RCSW-08 prescribes indoctrination, training and qualifications requirements f'r team members, and imposes NRC Regulatory Guide 1.58 and ANSI-N45.2.6 for such personnel.
Closed Followu Item 397/80-18-02
Instructions for reinspection of work completed within 90 days of June 2, 1980.
The licensee deter-mined that this inspection work would not significantly contribute to improvement of work methods, in view of extensive procedure reviews conducted as part of the RCSW restart efforts.
This is discussed in the WPPSS December 1980 and March 1981 progress reports, and in paragraph 15 of IE Inspection Report 50-397/81-01.
(Closed Unresolved Item 397/81-05-01
RCSW Task Force consideration of all issued and pending ProJect Management Instructions (PMI) in reviews of contractor restart procedures.
The licensee has issued controlled copies of the PMI manual to the contractors, along with identification of which specific instructions are applicable to each contract (WPBEC-2-81-17 dated March 20, 1981).
Task force personnel have now included the latest identified PMIs in their reviews of the various contracts, including contract 8234.
Representative review results appear in memoranda RCSW-81-470 (dated March,10, 1981)
and F-81-1376 (dated February 13, 1981).
The inspector interviewed the RCSW Task Force member responsible for resolving this matter, and was assured that each contractor has now been evaluated relative to the PMIs in questio Closed Unresolved Item 397 81-05-04:
Evaluation and repair of lack-of-penetration condition of existing weld on the sacrificial shield wall.
The engineer has issued technical direction PEO-215-W-A079 which prescribes removal of visible or suspected interface (lack of penetration),
including grinding, installation of packing bar, welding and grind flush, and magnetic particle examination of the repair area after completion of the weld.
Inspection by quality control inspectors and welding engineers is also prescribed.
The inspector observed progress on the grinding work, and methodical controls to assure compliance with the technical direction.
No deficiencies were identified.
14.
Nana ement Heetin s
The inspector met with the WPPSS site guality Assurance manager on April 3, 1981, to summarize his inspection findings and to receive a status report of principal WPPSS activities.
Attendees at this meeting are identified by notation (*) in Paragraph 1 of this report.
The inspector also met weekly with the equality Assurance manager to discuss status of his inspection efforts.