IR 05000397/1981016
| ML17276A132 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/24/1981 |
| From: | Dodds R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17276A131 | List: |
| References | |
| 50-397-81-16, NUDOCS 8110230490 | |
| Download: ML17276A132 (24) | |
Text
.S.
NUCLEAR REGULATORY COMMISS OFFICE OF INSPECTION AND ENFORCEMENT Report No.
50-397/81-16 Docket No.
50-397 REGION V
License No.
CPPR-93 Safeguards Group Licensee:
Washin ton Public Power Su
S stem P. 0.
Box 968 Richland, Washin ton 99352 Faci1 ity Name:
Washington Nuclear Pr o ect No.
(WNP-2)
Inspection at:
WNP-2 Site, Benton Count Washin ton Inspection conducted:
Inspectors:
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August 13-31, 1981 en> r esz. ent Inspector ~
Da e igned Date Signed Date Si ned pproved By:
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si 1e Reactor Construction Projects Section
te igned Summary:
Ins ection durin Au ust 1981 Re ort No. 50-397/81-16 Areas Ins ected:
Routine, unannounced inspection of licensee and contractor activities to re-evaluate and improve detailed work methods.
The inspection involved 30 inspector hours on-site by the resident inspector.
Results:
No items of noncompliance or deviations weve identified.
8110230490 810929 PDR ADOCK 05000397
<8 PDR Ry Form 2lg (2)
DETAILS 1.
Persons Contacted:
Washin ton Public Powev Su
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"'R. T.
"B. A.
A. M.
W. G.
R. T.
P. A.
Bibb, WNP-2 Project Managev Johnson, Pvoject Quality Assurance Manager Holmbevg, Deputy Project Manager, Engineeving Sastry, Deputy Project Manager, Special Projects Keltner, Acting Deputy Pvoject Manager, Construction Grant, Manager, Construction Quality Havness, Managev of Field Engineering Buvns and Roe En ineevs (BGR)
"A. T. Luksic, Licensing Engineev, Site Bechtel Powev Cor oration (BPC)
D. R. Johnson, Manager of Quality
"D. K. Cosgvove, Quality Assurance Engineer Wri ht-Schuchart-Havbor/Boecon Cor./Geneval Ener Resources Inc.
WBG P. Webster, Managev of Quality Assuvance
'C. Fox, Quality Assurance Audit Manager (Corpovate)
S.
Y. Young, Engineering Manager B. Seabuvy, Manager of Engineeving A. Keck, Materials Supervisov H. Buchanan, Quality Assurance Engineer, Receiving Havtfovd Steam and Boilev Insurance Com an W. Kane, Authorized Nuclear Inspectov (WBG)
M. Coates, Authorized Nuclear Inspector (Bechtel)
Other Geneval Contact and Notes D
In addition to the persons identified above, the inspector inter-viewed personnel from theconstvuction, engineering, and quality contvol site contractov organizations.
Various cvaft and super-vision who were present in, the work areas were also intevviewed during the inspectov's plant t'ours.
Denotes pevsonnel pvesent at the monthly management meeting.
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s Pro ect Personnel 7i During this period the. following key pevsonnel changes were made on this pvoject:
b.
a.
The WPPSS Deputy Project Manager for Construction, Mr. G.
Wells left the site, to be r eplaced by H. Cr isp, with W.
Keltner acting temporarily.'.'he WPPSS" Deputy Pwoject Managev,,'for Special Pvojects, Mr. A.'astry," leftI'theI> site, and'he special projects organizati.'on was'dissolved.
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A Bechtel,Transition Team,'Coordi'nator"'has been assigned to work with. WBG...'r, Neil>~Powel3...'h'olds this position.
d.
The WBG Project'u'al'ity'Assuva'nc'e,Manager, Mr. H. Brenner, left the'site:,to
&e'replaced.,by Hx. Paul Webster.
tg, General
The xesident inspectox was on-site'ugust 13-14',
20-21, 24-28, and 31.
During 'this peviod, the inspectov perfovmed routine examination of the site activities,, including plant tours, follow-up record reviews, and interview of personnel relative to status of engineeving and constvuction efforts.
A regional office inspector also visited the site during the first week of this peviod, when the vesident inspector was on leave.
A Regional Office team of inspectovs arvived on-site August 31, to commence a special inspection of the quality assurance progvam implementa-tion.
Bechtel Transition Activities On August 28, the licensee announced that contvact changes had been made to transfex'o Bechtel Covpovation, the remaining in-stallation work now assigned to the mechanical contractor, WBG.
This was stated to be consistent with the originally announced x'ole of Bechtel as the Systems Completion Contvactor for WNP-2.
The WBG ovganization is to vemain assigned as the mechanical contractor of record, and is to continue with review and comple-tion of quality vex ification documentation fov previously puvchased ov field installation items.
WBG is also to support the as-built pvogvam by pvoviding field engineeving staff, and is to complete activities necessary to supply matevial to Bechtel, which is pre-sently in warehouses ov on ordex'.
The contract includes continuance of the practice of WBG pvoviding quality control inspectovs for Bechtel.
This was pveviously identified as a program weakness by the resident inspectov, veference 397/Sl-ll-Ol.
The issue identified at that time involved the organizational independence of quality control inspectors.
The inspectors may be assigned to
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re-inspect WBG pveviously'ompleted work, undev conditions wheve WBG retains the contractual license to terminate such inspectors for alleged violations of job-vules.
On the Friday morning of August 28, WBG arranged for all files within WBG to be Locked/secured, and no personnel weve permitted to draw records from such files.
This was intended to prevent any incidents arising from pevsonnel reactions to the announce-ments forthcoming that day.
Late in the.movning, the crafts and inspection personnel were terminated by WBG, and left the site.
On the following Monday morning, Bechtel planned to perform hiring activities to the extent that immediate work activities would support additional personnel.
The inspectov toured the site, and intevviewed vavious pevsonnel, and in spite of high frustvation levels of personnel, there appeaved to have been no incidents affecting quality vecovds or work'.
WPPSS has appointed a~'transition team, with vepvesentatives from WPPSS, WBG, Bechtel, and Burns 6 Roe.
The Pvoject Managev assured the inspectov that the team will give consideration to implementa-tion of commitments previous'ly made, to the NRC velative to mechanical system activities,, when'uch',a'ctivities were under control of WBG.
1g WBG QA Personnel ualifications 8 Tvainin r,-,
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Quality Control-'Insp'ecto'v.
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'il The inspector"~intev'viewe'd'he'BG>,Quality Contvol tvaining coordi.na't'oi','and, examined typical "tva'ining logs and record files.
The coovdina'to'v, stated.that each new inspector is cevtified~.in,accovdance,with the ANSI-N.45.6-1978, as de-scvibed in his< inCeinal <<i~ns4vuction QCI-6.
Additionally each new.inspecto'v," must'.aompl'etc
'a'sevies of technical classes-pvio'v"to~'"be'ing cevtified,',,"regardless of resume or expevience.
' Additionally",each inspector is required to complete tvaining in the WBG pvoceduies applicable to the WNP-2 site "and the particular"-di'scipline being certified (i.e., mechanical equipment, civil, and welding).
The inspector visited the Quality Contr'ol tvaining facilities and the WBG general. training facility, including two pvo-
'edures/veading rooms in 'the veactov building.
Also examined wer e vecovds of personnel training requir ements, training completed, and tvaining classes outstanding for vavious individuals.
The zesouvces allocated to training of personnel, including instructovs and facilities, the tracking of personnel status, and the, extent of training appeared to be satisfactovy.
However, the inspectov identified a minov depavture from the approved governing proceduve WP-157, revision 12.
This pro-ceduve was veveiwed and appvoved by the WPPSS task force and
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incovpovates the NRC Regulagovy Guide 1.58 exception to ANSI-N45.6, thus requiring minimum of high school or General Educa-tion Development equivalent for any inspectov.
The WBG inter-nal instruction QCI-6 does not include this requirement, although the instruction had been appvoved by the WBG QA Manager and the Engineeving Managev.
The WBG Quality Control training coovdinator reviewed his vecovds and found that he had cevtified only one inspectov who did not have a high school degree.
Although he felt that other factors compen-sate for this, he had not effected any recovd of objective evidence of such an evaluation of the exception, as required by WP-157, nor had he included pvovisions-contvols for such evaluations in his intevnal instruction QCI-6.
However, the pveviously descvibed on-site training and examinations are documented, and appear to represent evidence of comparable/
equivalent competence.
The procedural omission of the high school vequirement is contrary to the RG-1.58 intent of high school education as a baseline requivement.
Subsequent to this finding, WBG issued vevision 1 to the QCI-6 internal instvuction, incovporating the omitted high school pvovision of RG-1.58 and WP-157.
Coincidentally, on August 28, all. WBG quality control inspectors weve term-inated, due to the Bechtel transition, such that the question-able inspectov became a moot point.
Bechtel new hives, and WBG new/vehires will need to be evaluated undev cuvvent critevia in effect at that time.
This appeavs to resolve the specific issue.
Quality Assuvance Audit Manager Qualifications The inspectov examined the resume, personnel file, and tvaining vecovds of the vecently assigned WBG covpovate Quality Assurance Audit Manager.
The records did not in-clude vevifiable evidence of qualifications of the individual as a lead auditov, as required by WBG: pvoceduve QAP-363.
The vecovds did not indicate any experience in scheduling, planning, ovganizing ov'conduct'ing audits or an audit piogvam.
The approved procedure QAF-363 requires lead auditov certif'i-cation and tvaining to the extent necessary to assure com-petence in. auditing skills, such as.qualifications to ovganize and direct an audit', vepovt findings, and evaluate covvective actions.
The QA 'inst'vuction QAAI-14 furthev clavifies the QA Audit'anagev,vesponsibilities and includ-ing tvaining, examination and';,certification of auditors, and job performance evaluation.'
The appointed manager, cuvvently holds a concurvent position as manager of the WBG'ite QA Systems Depavtment, which is
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responsible fov contvol and tvend analysis of deficiency reports.
He managed the deficiency veview activity associated with the WBG wovk methods ve-evaluations conducted over the past yeav at WNP-2.
The individual has held a position of this type for'bout two years, which appeavs to represent the extent of his divect QA experience.
Clerical, pvocedure prep-aration, equipment maintenance,'nd equipment sales experience constitute most of the individua1's backgvound.
The managev stated that he has not yet functioned as the audit managev, and has not signed, correspondence ov actions under this position.
He showed the inspector a memorandum.
from him to one of the lead auditors (CMF-125 dated August 5, 1981) which delegates his day-to-day Audit Department vesponsi-bility to one of his lead auditovs.
Xn addition to covering a peviod of his leave of absence, the manager stated that this memovandum was intended to extend thvu an undefined additional period, until the 'manager could participate in some audits and otherwi'se attain'sufficient experience to meet the qualification.vequirements of the audit managev position.
Aftev the Bechtel contvact change announced August 28, WBG covrected this issue by re'assigning the lead auditov to repovt directly to the corporate QA managev, pending completion of,'tvaining,of~the newly assigned audit manager
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This-'tem is'losed,.,;;,
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Mechanical ContvactovMateri'al Contvol'.:.
The inspecto'r,reviewed',documents.
and,intevvi'ewed personnel ve-garding contvol,,'of makevialsj supplied;by WBG to Bechtel, for its activit'ies'as.
Systems'Com'pit.tion~ Contvactor.
This also included r eview of",:.th'e~,'Pipe,.Whip restraint"'PWR)
mater ial release to Huico fov fabvicat'ion.'~
The~"in'spector found that the PWR material had been';sen~t>di.'meetly
.t'o'!Huico, and had been receipt inspected there, with;matevi,alIi'den%i.f3.cation inspection by a WBG vepvesentati'ye;,
'Th'at repvesentative'dentified that HUICO had *stavted f'abri;cation work, 'pv"cutting.fov veld pvocedure qual-ification test, s'pecimens, pvior "-to having. their veceipt inspec-tion and other pvoc'edures appvoved
~by',WBG.
Appvopviate sto'p work direction was-"given by WBG to Huico, comensurate with the WBG quality assurance pvogvam vequirements.
No advevse consequences were identified relating to this matter.
During this review, the inspector identified that WBG intevnal instruction (EG-12)
was issued, which under'mined the approved WBG pvoceduve WP-782 fov velease of matevials from warehouse custody.
The instruction designated the approved procedure as not applicable fov matevial supplied to Bechtel.
The WBG intevnal auditors identified this mattev in audit WBG-81-6, and effected corrective action.
The corrective action included plans to issue an immediate intevim engineering guideline Which pvescvibes the details of how matevial is to be released to Bechtel, to be followed
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by a procedure WP-820 fov Bechtel approval.
'Zhe auditor s appro-pviately insisted on a clear commitment date fov completion of this action, which was set at, September 15, 1981.
Additionally, the WBG engineering representative stated that the subject of sub-tier procedures would be included in the pending sevies of WBG 800 sevies procedures (scheduled to replace the existing sevies of WBG series, which have been deemed inadequate).
This item is common with the gCl-6 discrepancy described in paragvaph S.a above, as regards assuring that sub-tier documents do not effectively change the requirements of approved procedures without communsuvate veviews (as is required by Criterion VX of 10 CFR
Appendix B).
This matt'ev is unresolved pending review of the status of wovk activities aftev the August 28 Bechtel contract change, and the related applicability of the new WBG 800 series pvocedures and remaining sub-tier documents (397/81-'6-01).
A
'Plant Tours The inspector touved the safety related areas of the physical plant at various times between August 13-31, and performed follow-up vecovd reviews as indicated.
Pavticulav obsevvations are noted below.
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Electvicians wereinstalling a cable tray support at column line 15.9 of one dies'el,generatov voom.
Wovk packages in the avea included>'i'n-'process; inspection findings of vavious minor discrepancies which were being veworked.
The Fishbach 8 Lovd electrician had custody of a welding-electovde povtable oven, with lock and chain, and'olor coded electrode, to assure contvol of the E7018"material.
'No discvepancies were identi-fied, and pevsonnelintevviewed,'expvessed no quality concevas.
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WPPSS startup pj.pefi'tiers,'w'eve" i.'n>this~ same diesel genevatov avea, waiting foe.a,'matev'ial tvansfev,'ielease from Bechtel, pvior to 'j.'nstall'ing!'.a~ 6-".in'ch p'j.p'e,'-I'spoof.
No discr epancies were identified,, and,-<the "'personn'e1,'expvessed no quality concevns.
Two WBG ';pro'ceduves'-veview-wo'oms
.wev'e staffed by clevks includ-ing one at~ele'avation.
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'She.',log showed routine use of the refevence'atevial~by
'crafts,' with'the identification of par-ticular pvo'cedur es';i equi.'ewed~! 'he,;logs showed that pr ocedur es applicabl~e',,to,,c'uvvent pipe-hanger work (WP-281 and WP-330)
were refevred',to often.
Contvollecl copies of the procedur es.
were avai1able in these aveas'.
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t'y WBG pipefitter s wer e welding on Auxiliary Steam System 'pipe hangev AS-170 (safety',<<r'elated).
The applicable yellow work package was present at the work location, and the, hanger dimensions and welds appeared to be as specified in the work package.
The inspection hold points weve signed as requived
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f for the stage of work in pvogress.
The inspectov interviewed the weldev and the quality control inspectov relative to inspection cviteria and general work progress.
The inspector also latev veviewed the "red" wovk package for AS-170, and intevviewed the responsible WBG field engineev relative to bases for the wovk-avound decisions reflected by the outstand-ing issues documented in the red wovk package.
The ved wovk package demonstrated that there weie issues which would not be resolved until after completion of the installation, as provided by the appvoved WBG procedures.
No discvepancies weve identified, and per'sonnel expvessed no quality concerns.
A skin-plate of the sacrificial shield wall had been vemoved, the concrete excavated, and core samples of a radial weld weve taken by WBG.
The WBG stxuctuval engineer stated that this effovt was in response to the WBG inspection findings on a vadial weld duving the circumferential weld activities at elevation 540 feet in Januavy.
No discvepancies were identified relative to the excavation/coving activity, and personnel interviewed expressed no quality concerns.
8.
Re ovt of Diesel Generatov Buildin Undevminin The inspector received an anonymous'telephone repovt of excavation wovk east of the die'sel genevatov building as undexmining the foundation.
The inspectov inspected the area and noted no en-cvoachment under the'oncrete foundation pad of the building.
The excavation was neav the building, and a one-to-one slope of the excavation had not been achieved, but the licensee stated that. a nonconf'ormance repovt had been'vepared already fov this matter.
The inspectox'id'ot identi'fy any safety significant matters.
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,Re ovt of 'Im vactical Anchor-'.Bolt Ins'tall'ation Cvitevia A site employee,vepovted:
to,'the inspectov that the specifications for anchor-"bo'lt';,iristallation x equiie",setting of 3/8-inch diameter bolts to a,,dept'h 't'olexance.,of,~g/6)th inch.
The individual com-plained that this was v'evy di~fficult to achieve with hand-held concxete dril1s,,-'a'nd,v'ejection, vates w'eve high.
He did not feel that such a tight,.'tolevan'ce.,'twas 'nee'ded.'he tight'olerance did not appeav to'"be="a matter of safety concevn, thexefove the inspector conveyed the-employee's concevn'-to the WPPSS assistant constvuction manager for considevation by the. WPPSS'-Hotline activity.
The employee was agx'eeable to this handl'ing, and was made aware that if he,wanted a pevsonal explanation of the result of the WPPSS veview, he could have it by contacting the Hotline himsel n I
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Re ort of Tem ovar Conduit Installation Above Safet -Related Items l(
A site employee reported that three years ago a temporary tele-phone conduit was insta13.ed between manhole El and the switching room in the radwaste b'uilding.
He repovted that the conduit was still there,'nd he-was',.concerne'd that it may fall on safety related equipment.
,The indi'v'idual identified the foreman who had wovked on the.'oqigi;nal "installation, who was still on-site.
The inspector 'intyvvie'wed,.t'e'oreman,-and:'traced the installed conduit through the'lant., ',The, conduit did 'not appear to be routed ovev
- or neav any seismic'esigned or other safety-related equipment, although it d5.P.'shhr'eisupports withvarious permanent plant equipment in,,the "xadwaste: building.'he foreman stated that no design proceciures'ere
'involved in this~installation and the electricians
's'imply 'installed the, conduit". to their usual industvial practices.
'Xh4'nspector identified no~s'afety-related concern with this, specie'ic,'tem.
He advised",the WPPSS assistant construc-tion manager of~the existing details'f this mattev, for consid-eration undev the WPPSS Hotline program.
He also introduced the general question of controls ovex pveviously installed temporary items in safety-velated aieas.
The question of tempovary attach-ments to piping and stvuctural steel has previously been addressed by NRC/WPPSS, and acceptable vesolution identified.
The assistant construction manager agreed to advise the inspectov of'is findings velative to vemoval contvols.
This mattev will be further examined at a futuve date (397/81-16-02).
Alle ed Destruction of ualit Records An individual contacted the resident inspectov to advise that within WBG,.one page of a log was recopied to delete evidence of receipt and review action on a vendor pxocedure.
The allegev did not identify the specific page, the specific log book, the specific proceduve, nor any rationale for eliminating evidence of receipt of, the procedure.
The allegev felt that the recopying of the log was impxoper.
The inspector identified no impropriety nov noncompliance with progvam requirements.
fh The alleger also advised that a
WBG individual had stated that he had put some vendov procedures into the tvash to eliminate them to avoid possible audit findings to the effect that the identity of the procedure reviewevs could not be determined.
Again, the allegev could not identify the specific procedures involved, except that they weve dated pvior to Januavy 1981.
The alleger admitted to no direct knowledge that the events actually took place.
The allegev did claim to have personal knowledge that the logs of procedure xeviews in some cases did not provide sufficient identi-fication of the pevsons who performed the reviews.
In particulav,
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in some cases only the initials of the individual were purportedly recovded, and these could not be tvaced to the person's identity.
The inspectov interviewed seveval WBG personnel regavding handling of vendor pxoceduves for veview.
These included the equality Assurance Managev, Pxocuvement Manager, Purchasing Agent, Material'ontvol Supervisor, and a receiving inspection quality assurance engineev.
The equality Assuvance Manager also assigned a quality assurance auditor to research this mattev and document his find-ings.
None of these pexsonnel indicated any knowledge of permanent quality vecords having been discarded.
The inspector determined that vendox procedures ax e distvibuted by the purchasing agent to the Matevial Contvol Supervisov (which the puvchasing agent considers to, be part of the Engineering gvoup),
who in turn distributes the procedures to Engineering,and equality Assuvance for review and comment.
Evidence of review by each organization is maintained via managev sign-off on the tvansmittal/
.approval stamp.
The identity of individual reviewers was not pveviously maintained, nov weve logs of distribution maintained by the Material Control Supervisor.
Howevev, a recent Bechtel quality surveillence veport documents this weakness in control and calls fox'
procedure revision to improve the practice.
The receipt inspection quality assurance gvoup cuvvently maintains a log of individuals who have been assigned the vesponsibility for quality assurance veview of individual vendov procedures.
This group also maintaines some copies of the procedures, however, the official copies ave maint'ained by the document contvol gvoup.
The inspectov determined that'he alleger was vefevring 'to act-tivities of the quality assuvance group only.
For any destruction of the pvocedures maintained by this group, theve appeavs to be no pvohibition, since the"~vecovd copies are maintained elsewhere.
There was no evidencethat',the'~alleged destruction had occurved.
Howevev, the,,wnspectov di'd -nota tha'tthe identity of individual veviewers was-.-not.we11 documented, in,'.,the past, so as to introduce some complicate:ons in,the'"vevevification efforts planned by the licensee for..%his project';
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The inspect'or",did 'not.'CVbs4anti'ate,<'ny'oncompliance with regulatory requirements nor 'dev3.ations,,suggested;by the alleger
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Licensee Action.,OnPvevious Kns ection',Findin s
(Closed)
Unr e'solved lImon'th"-end management meetings would be addressed to 'th'e Project., Manager, with additional attendees as he would vequesg.
The monthly -manhg'ement. meeting was 'held on,August 28, at which time the inspector. presented his findings and summarized activities conducted duving'th5.s veport period.
The Bechtel representative presented to the inspectov summary packages vepvesenting the Bechtel position on thvee
.pveyious NRC inspection findings.
The Project Manager descvibed the Bechtel contvact change to assume mechanical systems completion work.
Attendees at. this meeting are identified (
) in paragvaph 1 of this repor r
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Nashington Public Power Supply System-2-SEP 8 9 1981 to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the repox't vill be placed in the Public Document Room.
Should you have any questions concerning this inspection, ve will be glad.to discuss them with you.
Sincerely, B. h. Faulkenberry, Chief Reactor Construction Projects Branch Enclosure:
XE Inspection Report No. 50-397/81-16 cc w/o enclosure:
M. C. Bibb. Project Nanager R.
B. Glasscock, Quality Assurance Director I
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