IR 05000397/1981018

IE Insp Rept 50-397/81-18 During Sept 1981.No Noncompliance Noted.Major Areas Inspected:Licensee & Contractor Activities to re-evaluate & Improve Detailed Work Methods

ML17276A545
Person / Time
Site:	Columbia
Issue date:	11/12/1981
From:	Dodds R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML17276A542	List: IR 05000397/1981018 ML17276A538
References
50-397-81-18, NUDOCS 8112290519
Download: ML17276A545 (42)

Text

Report No.

50-397/81-18 Docket No.

50-397 U. S.

NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION V

License No.

CPPR-93 Safeguards Group Licensee:

Washin ton Public Power Su ly S stem P. 0.

Box 968 Richland, Washin ton 99352 Inspection at:

WNP 2 Site, Benton County, Washin ton Inspection conducted: September 1981 z g..

ot, en's>

ent Inspector Inspectors:

Facility Name:

Washington Nuclear Project No.

WNP-2)

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/2.

8'ate Signed Date S gne Approved by:

R.

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o s,

hse Reactor Construction Projects Section

Summary:

Ins ection durin Se tember 1981:

Re ort No. 50-397/81-18.

Dat S gne Areas Ins ected:

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

The inspection involved 115 inspector hours on-site by the resident inspector.

Results:

No items of noncompliance were identified.

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Persons Contacted:

Washin ton Public Power Su

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Washington, Reverification Program Supervisor Wright, equality Engineering Supervisor C. Bibb, WNP-2 Project Manager

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T. Johnson, Project equality Assurance Manager A. Holmberg, Deputy Project Manager, Engineering A.'Crisp, Deputy Project Manager, Construction G. Keltner, Assistant Deputy Project Manager, Construction T. Grant, Manager, Construction equality A. Harness, Manager of Field Engineering J. Bufis, Test Group Supervisor D. Kassakatis, Test Group Super visor D. McBurney', Test Group Engineer Carlson, Preventive Maintenance Program Manager (WBG)

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Grazi ani, Operational'equality Assurance Supervisor A. Stanley, Project Engineering Management Specialist Burns and Roe En ineers BER)

• A. T. Luksic, Licensing Engineer, Site

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R. Schlosser, Project Engineer Mechanical/Welding R., S. Popielarczyk, Lead Mechanical Engineer K.

Hoopingarner, Senior Engineer H.

Theroux, Mechanical Engineer C.

N. Orsborne, Documentation Manager J.

Ketchum, Correspondence Control Clerk-Bechtel Power Cor oration BPC D.

R. Johnson, Manager of equality T.

A. Mangelsdorf, Project Manager.

M. J.

Jacobson, Project equality Assur'ance Engineer

• D. K. Cosgrove, equality AssuranceEngineer"'.

K. Cutright, NDE Level I,I,"Qual,i',Control Engineer ",

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Powell, Project Mariager (llBG) q l,';,,~;

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Scott, Documentation Manag'er~ (WBG),, ,;;,

Wri ht-Schuchart-Harbor/Boecon(Cor

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Webster, Manager of 'Qua'lity 'Assurance Fox, equality Assurance Au'di.t Manager -(Corporate)

Y. Young, Assistant to 'Pr'oject Manager( ),";

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Seabury, Manager'-o',

Engineering j"4 r,

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ft Fischbach and Lord W. L. Brown, guality Assurance Manager

-'g R. L. Golberg, Assistant Project Engineer

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A. Roselli, (}uality Assurance Field Supervisor Hartford Steam and Boiler Insurance Com an W.

Kane, Authorized Nuclear Inspector (WBG)

M.

Coates, Authorized Nuclear Inspector (Bechtel)

Other General Contacts and Notes In addition to the persons identified above, the inspector interviewed personnel from the construction, engineering, and quality control site contractor organizations.

He interviewed various craft and supervision who were present in the work areas during the inspector's plant tours.

• Denotes personnel present at the monthly management meeting.

Pro ect Personnel During this period, Mr. R. L. Knawa was assigned to manage the WPPSS guality Verification Program.

The Special Projects staff was also reorganized to reassign the staff to existing line organizations and then matrix them to the reverification group via special assignments.

Gener al The resident inspector was on-site September 1-4, 8-11, 14-18, 21-25, 28-30.

During this period, the inspector performed routine examination of the site activities, including plant tours, followup record reviews, and interview of personnel relative to status of engineering and construction efforts.

A team of regional office inspectors also visited the site during the period of September 1-4, to perform an announced inspection of the general quality assurance program establishment and implementation.

The annual meeting to discuss the NRC Systematic Appraisal of Licensee Performance (SALP) was convened with the licensee senior management in the WPPSS Richland offices, on September 17.

The arrival of the NRC independent measurements van was deferred, in view of recent licensee efforts to r'eview~radiograph records on file, and investigate discrepancies found, during this review.

Construction was reported to be 86/ complete.

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Plant Tours The inspector toured the safety related areas of the physical plant at various times dur ing the month, and performed followup record reviews as indicated below.

Particular observations are noted below:

a ~

b.

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The cement grout was cracked under pressure relief valve supports in the suppression pool.

The inspector interviewed Burns II Roe engineers who demonstrated that,this matter had been identified by contractor and licensee personnel prior to August 28, 1981 and action had been taken to obtain formal reinspection by inspectors qualified in civil work.

The engineers stated that the cracked grout would be replaced.

I Electrical contractor, personnel were pulling"l,arge diameter cable through conduit at a

HPCS Diesel Gener ator=switchgear cabinet.

The., inspector questioned the lack of, tensioning equipment, and interviewed quality control person'nel,who

'were mbpitoring the work.

The cable= had,'origina',lly', been ins'tailed too short, and was being removed for disposal.

.AlthoughI,ten'sion monitoring did not appear'to be necessary, for this removal, the contractor had assigned quality contr'o'1 personnel"'to perform g'eneral surveillance of the operation. ',",'...',

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.'v WBG field engineers, were encountered,';,who"pere performing walkdown reviews of the service.'water system,'to:determine,the presence or absence of components or parts of the piping'>>and,supports.

This was an inventory effort, to identify the work completed by the contractor and the work which was yet to be done by Bechtel after s stems turnover.

Y Other WBG engineers were performing =as-built drawing update work on part of the piping in the diesel generator building.

These engineers were supporting Burns IE Roe as part of an intensified effort to update construction drawings to actual configurations of installed parts to permit concise working drawings to Bechtel crafts and inspectors for the systems completion effort.

No items of noncompliance or deviations were identified.

5.

Bechtel Transition Activities On August 28, 1981, Bechtel assumed the responsibilities for completion of physical work on all of the mechanical systems previously contracted to WBG.

Bechtel has assigned coordinators to work with WBG, and to act in line organization senior management positions within WBG, to facilitate the transition of responsibilities.

Commitments to the NRC have been included in the transition team's routine agend I I1 (

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Mechanical Contractor WBG Activities On August 28, the mechanical contractor (WBG) terminated all crafts and Quality Control personnel.

During the month of September WBG has additionally terminated various support clerical, training, and field engineering personnel.

The WBG activities this month have generally been confined to reorganizing and attempting to determine the scope of remaining WBG work and the operating procedures for that work.

The remaining WBG prescribed activities involve reviews of existing WBG documentation, including identification of discrepancies, and, where possible, resolutions which can be accomplished without physical rework.

The WBG effort is intended to provide the ASME Code data reports for the portions of the, systems

'comp1eted by WBG.

These would then be accepted by Bechtel for completion of outstanding or incomplete work activities, a'nd incorporation into the final Code data reports as basis for the system N-Stamp.

The details of these activities have been defined by WBG and Bechtel, but the ASME authorized inspectors have not acknowledged acceptability of,'the tentative scoping plans to date.

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When WBG terminated the quality control inspectors, various inspection activities in-progress

'were reviqwed ',by their,supervisors in an attempt to clean-up loose ends'nd assuII e~that all Iipsiies have been included in the applicable'records files,." The inspector observe'ed preparations in mid-September to discard the QC-inspection working files of about 12 file cabinets.

The NRC'inspector identified.several folders of QC open surveillance reports'uring a quick survey of the files.

There was no indication that these findiqgs h'ad been 'incorporated into other plant files,'and-the QC supervisors,'ho claimed to have reviewed records for loose 'ends, were not at all'familiar with the documents which dated-back to, 1979.

The inspector advised the WBG QA manager, the Bechtel Project QA Engineer, and the licensee QA Manager of this situation.

The

'HBG QA manager decided not to dispose of the files and had them moved to a storage location.

He stated that the open surveillance reports and similar data would be incor porated into the applicable corresponding work packages.

The inspector stated that this matter would be examined further while work is in-progress.

This item is unresolved pending such review.

(397/81-18-01)

7.

Bechtel S stems Com letion Activities Bechtel has proceeded with fabrication and installation of some parts of safety related mechanical systems.

These activities are based upon results of system walkdowns.

Bechtel has suspended work on mechanical systems, in order to improve procedures and training of personnel in response to concerns expressed by the Bechtel ASME authorized nuclear inspecto i

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Reverification Pro ram Status a ~

Licensee WPPSS Reverification Activities The WPPSS part of the reverification program includes overall administration of the program, including preparation of overall policy and instructions and monitoring of the Bechtel activities, plus the completion of specific tasks.

Three tasks had previously been defined, involving review of previous contractor work in the areas of:

(1)

Receipt Inspection (2)

Personnel gualifications (3)

Deficiency Document Dispositions

'nly the deficiency document review activity has apparently been worked thus far.

This has included selection of a group of NCR's (nonconformance reports)'-and referral of these to the WPPSS corporate office engineers for-evaluation,'of the technical aspects of the disposition of the questions involved.

The RVP personnel stated that a random sampling technique was,'not us'ed for'selection of the NCR's, but;rather the selection,'was,weighted

.by personal evaluation considerations.

The RVP,, Supervisor stated that other deficiency documents

'were also being"eva]uated for"review of dispositions (e.g

, Request For.Informatio'n, submitted by contractors to the architect-engirieer for, engineering, decision).

At this time, the RVP review has,,not i'dentified any apparent trend or other basis for concluding that inadequatetechnical dispositions were made on NCR's

The inspector n'oted that ongoing contractor intensive document, reviews also involved reviews of NCR's and simi lar documentation, and that there is currently no provision for drawing adverse-trend information up to the attention of the RVP staff, either in WPPSS or in Bechtel.

The inspector identified the sampling basis, the conclusions reached, and the lack of communication channels to contractor review-functions as areas of suspected weakness in the program.

This area will be examined in the future.

(397/81-18-02)

b.

Bechtel Reverification Activities Bechtel has assigned an individual in the construction management organization to coordinate the reverification program.

Bechtel has held a briefing meeting with each of several contractors to discuss the reverification program.

The Supply System and Bechtel intend to have the contractors plan, organize, and conduct the reverification activity under the surveillance of Bechtel.

Each contr actor has been provided a copy of the /VI-01 procedure

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as a basis from which to conduct his,planning.

At this time, there is neither detailed gui'dance to",the conti actors nor details of the Bechtel surveillance functi'ons,.".Each contractor has been requested to submit" h',is,p'lan to Bechtel

'for review and approval.

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',a typical briefjng meet'i'ng 'with the fire protection system contractor (8217 Sentry)..

.The WPPSS RVP Supervisor also attended this, meeting,',as his first such, participation.

The contractor had,one-engineer on his,staff who'would be charged with the responsibility for developing the reverification plan.

Very little safety related mechanical work has been installed; therefore, the scope of this aspect would be limited.

However, the contractor noted that his system was unique in-that he had a target of January 1982 to make his system operational and that an evaluation had already been made that the reverification work would occur after system turnover.,

He indicated that his engineering resources were limited unti 1 after s'stem turnover.

Bechtel encouraged him to supply his plan within two weeks.

The WPPSS RVP'upervisor stated that initial contractor responses had not been as thorough as had been hoped and that further actions would be necessary.

He stated that the WPPSS RVP staff would become more closely involved in the monitoring of this activity.

At this time, no provisions had been made for obtaining RVP related information from contractors already engaged in ongoing review or inspection activities.

However, the WPPSS RVP Supervisor has instructed Bechtel to initiate action to evaluate PDM's previous review/reinspection effort (which had been conducted during 1980-1981), to determine how much RVP credit could be given for that activity.

This evaluation is to be accomplished in accordance with guidelines established in an approved RVP procedure.

The procedure (/VI-05) requires consideration of the scope of the contr actor's effort and the degree of participation by licensee representatives.

(The inspector had previously expressed concern that the results of the contractor's internal review efforts may be insufficiently monitored by the licensee.

IE inspection report 50-397/80-16 paragraph 5 expressed the concern that the licensee determine the extent of such efforts and report these to NRC.

Summary reporting commenced with the licensee's bimonthly report to NRC, relative to the 10 CFR 50.54(f) inquiry).

At this time, the reverification program appears to be receiving increasing licensee and Bechtel attention and is in its early mobilization stages.

There is insufficient progress to assess conformance with the commitments of the licensee reply to the 10 CFR 50.54(f) inquir I I

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Service Water S stem Records An NRC regional office team inspector identified that two valves (SW-V-4A and SW-V-4B) had some obvious minor discrepancies consisting of missing bolts and a missing hinge on the valve motor operator assembly.

The inspector interviewed the preventive maintenance'ersonnel of the electrical and the mechanical contractors (WBG and FKL) and the Bechtel systems-completion engineers and coordinators.

He examined the WBG preventive maintenance records for February 1979 to June 1981 and ascertained that the observed discrepancies were identified in this documentation.

A record of the conditions was documented on a

Package Completion List (PCL),

a copy of which should also have been filed in the official work packages for the valves.

The PCL did not appear in either the Bechtel copy of the work packages, nor the WBG copy of the work packages.

Also, the content of the WBG work packages was not the same as the Bech'tel co'pies; 'However, the licensee affirmed

,that instructions have now'een given',-.to',return the; Bechtel copies to WBG for consolidation,and resolution~ of-differerlces)..

The conditions identified on the preven'tiv'e main'fenance",,PCL were in'eluded on one of several different PCL"'s'filed in',--"the.'BGiworkpackages,,and the conditions did appear on the Mech'anical'sy'stems,'aster)Wor'k~List'MWL')

for the project.

However,> itwas','notevident'if'iden'tjficationf the conditions arose from the now lo'st copy. of, the preventive ma'intenance PCL, or rather from a recent system.'wa"i[<down" irispection'activity';

The inspector could identify no convincing evide'nce that-"the'preve'ntive maintenance PCL s were being filed into th'e'pork'ack'ages for-eventual resolution.

The licensee reviewed and'onfirmed,'the,cojdition. and,identified current plans to provide both'-the basic.work package~'and the; maintenance package to Bechtel for r eview'during'ystems completion/turnov'er of WBG work.

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The licensee also agreed to:r'eview apparent conflicting instructions for handling minor discrepancies found during preventive maintenance actions as documented on WBG internal CAR-206 and Burns E

Roe response to a Request For Information RFI-215-M-7577.

The WBG position provided for documenting certain conditions only on PCL's, with eventual correction

'fter system completion and walkdown.

The BKR position required a

nonconformance repor This maintenance activity was assumed by Bechtel in September.

Current instructions provide for the use of PCL type documentation with BM concurrence.

The inspector identified no items of noncompliance regarding this matter.

10.

Unistrut Boltin on Emer enc Power 24-Volt-Batter Rack Rework The NRC regional office team inspection leader requested the resident inspector to review the battery rack rework activities.

This work was being performed by WPPSS startup/operations personnel, rather than the prime electrical contractor on-site.'The system had been

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provisionally accepted from the contractor, and documented in package number 50.3-P1.

Outstanding deficiencies were documented on reports of nonconformance (NCR's)

and related project engineering directives (PED's).

Specific items included battery connector damage, rack anchor nut insufficient engagement, and improper torquing of assembly bolts.

The battery rack supplier (Exide) installation instructions were available and were used for and referenced in the procedures developed for the rework.

Elements of the procedures included torque wrench calibration, witness of torquing values, specific torque values required, and snugness of fit of batteries and spacers in the racks.

The inspector examined the following records relative to the above:

Provisional Acceptance Package 50.3-P1 Procedure SLT-S50.3-4 for Racks BO-1A and 1B Procedure SLT-S50.3-5 for Racks BO-2A and 2B Test Change Notices S-50.3-4/TCN-1 and S-50.3-5/TCN-1 P ED-218-CS-3967 I

P ED-218-CS-4079 NCR-206-2328

'CR-218-4284 NCR-218-7877 Exide Installation Instructions for Batteries and Racks (58.01, 58.04, and 58.06),

and Installation Instructions for Seismic Resistant Racks The inspector examined the racks and the adjacent 250-volt-battery racks.

The adjacent racks had been previously completed by the prime electrical contractor.

They also, contained discrepancies which were scheduled for rework by)the'l<PPSS'oper'ations staff.

There was an anchor-bolt missing from"the reworked BO-2A/2B r'acks

"and insufficient thread engagement in an. anchor bolt nut',for the'O-1A/1B racks; however, the NCR/PED records demonstrated,,th'at th'is condition'gad been evaluated and accepted by the~des'igner,;,(Burns" E'oe),,One'additional case of incomplete anchor-,bo".I,t'.eng'agemenP

<<was'ccepted by,ithe, test engineer on the basis of a ininimu'm 4-'hrea'd engagements'criter,'ia defined by the Burns 5 Roe engineer,thru-reference,to~the-.electrical contractor's procedure CP/gAP-505.

A'he inspector observed'.that one of the<spring-n'uts for the BO-lA/1B strut assembly had rotated'90-degrees'du'ring

'installation and slipped between the channel"runners. so's not to hold" a'. Toad

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Another spring-nut had rotated 60-degrees, introducing question as to'.its load capacity.

This condition was corrected in the presence of t4e inspector.

Also, the test engineer issued Test Change Notices and. stated that the procedures for additional battery rack rework'would incorporate inspection criteria for this item.

The inspector had no further question regarding the technical disposition of this ite C jf t-l I

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II The inspector observed this same nut, rotation'ondition on the 250-volt-battery racks in several places.

These racks were scheduled for rework which should correct this condition under the inspection criter ia addition discussed above.

However, the existance of the condition on completed work by the electrical contractor implies a

generic weakness in the installation/inspection procedures of this contr actor in other applications of the strut/spring-nut configuration.

The electrical contractor surveyed the nature of his installations and inspected some further installations in the plant.

He stated that the battery racks were not a totally typical installation.

However, the contractor stated that a verification of this item would be included in the procedures which are to be used during the retorquing and bolt replacement program currently underway.

The inspector found this to be an acceptable preventive/verification action.

The WPPSS quality assurance manager stated that this matter will be referred to one of the task forces involved in resolving anchor bolt evaluations, to assure consideration of piping supports which are supported from embedded or other unistrut type anchor points.

This matter is unresolv'ed pending review of verification/evaluation activities described above.

(397/81-18-03)

No items of noncompliance or deviations were identified relative to the above.

Startu-Work-Re uest/S stem-Lineu -Test Procedure A licabilit The battery-rack rework described above was managed by the WPPSS startup organization.

The test engineer elected to write a System Lineup Test procedure to govern the work.

This procedure was reviewed by the Test Working Group (TWG) prior to the work in accordance with procedure TSP-7.

The TWG is a comnittee which includes the operations gA representative.

Upon completion of the test, the procedure (checklist)

is signed by the test engineer and reviewed by the Test engineer's supervisor.

The completed results are not reviewed by the TWG nor the gA representative.

An alternative administrative approach could have been to issue a

Startup-Work-Request,(SWR)

in accordance with procedure TSP-12.

Procedure TSP-12 states that the SWR "shall be used to authorize repair, rework or modifications to systems or components after Provisional Acceptance until Release for Operation;...."

It requires gC inspection/coverage in accordance with the procedures, of the organization performing the work.

It requires review of the work'rocedure by the test engineer and the operations gA representative; and review of results by either the construction or the operations gA representative, as applicable, and approval by the Startup Manager.',

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completion or rework of permanent plant installati'ons, at least.:in,its charter: 'he mechanism for achieving such modifi'cation appe'ars"toi,be='the Startup Work Request, for obtaining construction,.,related

'services".from the "construction organization or its c'ontractors,.

-,iFor ',the~ battery rack rework, the test engineer, his su'perviso'r,,",and

~the TWG,'chairman for" the work stated that the SLT was ade'quate and an "SWR w'ould not','normally, )be,;issued for work administered within,the~'Sta'rtup Group itself.

The'<applicable startup procedures each contaijed 'their,"own uniqueness'n pre-work and post-work reviews, and,'he procedures'were~ambiguous as to which were mandatory for situationssucli;as,the batt'ery. r'ack-rework.

The inspector accepted the records as-;is 'onth'e-.basis'~that

'an Engineering representative and the'Operations gA representative"sat'-'on the TWG committee and could have 'requested

'an SWR, if.considered':to be appropriate.

I However, this matter demonstrates how the Startup',.Group may provisionally accept a system from a" contractor, wit),various deficiencies remaining outstanding, and then itself performer'cwork or repair of the hardware.

The Startup Group may omit invoking the 'contractor's gA program controls.

(For the battery racks, the startup engineer demonstrated that he had considered the vendor's installation instructions, the contractor's gC procedur e in the preparation of the SLT, and had coordinated with the Burns 8 Roe engineer).

The TWG engineering representative is responsible to assure review of SLT's by appropriate engineers.

As a result of a surveillance by the Operations gA, (SR-2-81-6),

the engineering responsibility was clarified in memorandum F-81-6281, to include review of technical compliance with WNP-2 design specifications.

Changes to the Operations guality Assurance activity appeared to be imminent to clarify the gC inspection functions and interfaces.

Such changes are described in a planning memorandum 0(A-SLG-81-156 (dated September 8, 1981),

as are clarifications in Test and Startup Procedures revisions currently under review.

These will be examined in future inspections.

(397/81-18-04)

Or anizational Inde endence of Startu Work Ins ection Activit For the battery-rack rework, the WPPSS test engineer provided technical direction to electricians who were assigned from the operations maintenance organization.

The test engineer also performed the quality verification and hold-point sign-off for the procedure which he had prepared.

His independence from cost and schedule constraints and from the individuals/

group performing the work appeared to be somewhat compromised by the technical direction role.

Aside from the spring-nut matter discussed in paragraph 7 above, the inspector identified no particular quality concern with. the battery rack work. It was considered to be a'ery limited work operation.

(It is not, apparent that more -independent gC inspection would have identified the spring problem, as evidenced

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-11-by the existance of a similar problem with the original racks).

The organizational relationships appear to be subject of a current WPPSS study, as indicated in paragraph 8 above.

This matter will be examined during future inspection activities.

(397/81-18-05)

13.

Licensee Review of Radio ra hs of Mechanical Contractor Bechtel had performed a sampling review of about 110 radiographs, which represented those in the permanent files from WBG.

The results of the review were documented on June 24, 1981.

The reviewers identified questions of weld integrity and film quality, as apparently being contrary to the applicable ASME Code.

There were 16 film quality questions including (1)

5 cases of density variation limits, (2)

cases of missing views, (3)

1 case of penetr ameter omission in one view, and (4)

3 cases of excessive size of penetrameter used.

There were 15 cases of weld integrity questions.

These were reviewed by NDE level III personnel of WBG, Bechtel and WPPSS, with 7 deemed boarderline acceptable.

The remaining 8 were deemed to have weld root indications which could not be justified as obvious geometry r elated, as opposed to lack-of-fusion type indications.

The indications are dark, clear, and linear and appear at the root fusion-line where lack of fUsion or similar defects could conceivably be masked.

This matter has been documented by Bechtel on MCAR-1, dated August 4,

1981 (BECWNP2-81-0186).

WPPSS responsive instructions were to cut out three welds for physical evaluation (WNP2BEC-81-720, dated August 24, 1981).

The following three welds were selected:

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c, HV-668-1.5/FW4:

This item is a 20-inch carbon steel weld of the heater-vent system, non-safety-related, ANSI-831. 1 Code.

It was one of the welds selected by WBG for random radiography, required by the project specification.

It showed clearly unacceptable indications, such that it was already scheduled to be repaired by removal.

(The inspector noted that this radiography was performed recently by WBG on July 6, 1981, after the WBG restart program reviews discovered that WBG had originally failed to perform in-process 10K random radiography during earlier erection activities).

I RHR-867-12.16-W14A:

This is a 6-inch'ASME bi-,metallic weld of carbon and stainless steel-.

It is not typical, of most welding in the plant, although it is representative of'some.

Its radiographs show a dark line along the carbon" st'eel base-metal/weld fusion line corresponding to the root, location:

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This is'" an 18-inch carbon s'teel weld, typical of many.

The radiograph'-shows dark linear indications along the fusion line of the roo 'f'fft'trr Y'8')

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-12-The initial review conclusions were examined by NDE Level III individuals from WBG, Bechtel, and WPPSS.

They concluded that the welds may not be unacceptable, but, objective evidence was not available upon which to base such conclusions.

The cut-outs were made in mid-September, with subsequent WPPSS laboratory preparation of polished cross-sections for engineering evaluation.

The inspector examined these samples, reviewed the associated radiographs, and interviewed the laboratory personnel and the Bechtel NDE level II personnel responsible for review of radiographs.

This matter is still under review by the licensee, and will be examined further by the NRC.

(397/81-18-06)

Pi e

Su ort As-Built Drawin Pro ram The inspector interviewed the WBG as-built program manager regarding the scope and objectives of the ongoing WBG as-built drawing program.

Also examined were current as-built files and examples of installation discrepancies being found by the field engineers.

Installations contrary to the original design and to approved design changes have been found which support the WBG earlier gA review conclusions that the vaulted as-built drawings warrant verification.

The inspector reviewed the as-built status of the drawings which had been transmitted to Facility Design Engineering (Engineering Technology Engineering Center)

by September 9,

1981 WPPSS letter NS-L-02-RHN-81-036.

These drawings were part of data which NRC 'had requested WPPSS to furnish (July 22, 1981 letter) for confirmatory piping analysis for WNP-2 safety relief valve discharge line number 10"HS(18)-2.

The request identified the purpose as including verification that WNP-2 has correctly modeled its piping, correctly used its, computer codes, and had adequately accounted for the piping,',s as-built condition.

The inspector found that of the 53 pipe supports listed by Burns 5 Roe, the as-builts.,had been prepared for only 15.

,Of the remaining 38, there were 22 'documented as having installation complete, but not as-built.

Because of general recognition,'that the as-built conditions of the mechanical systems may not 'be accurately reflected in permanent plant records at 4NP-2, the"'inspector examined.the ne'wly available as-built drawings for three-'ins'tailed supports'.

In each case, the as-built condition was not as'hown on the design drawing and the design changes which had bee'n submitted to, the, NRC's consultant as follows:

a.

Hark PHS-333:

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The as-built condition shows that the spring support is mounted on a horizontal 4x4x3/8 x 17.5 cantilever, which is, welded to a horizontally braced 4x4x3/8 column.

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The original design (and approved change)

show a variable spring hanger mounted to a vertically braced, 5x5x3/8 x 20 cantilever.

The as-built condition shows that a 5x5x3/8 x 9-5/8 lateral piece had been added to move the hanger support point horizontally 8-3/4 inches.

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Mark PMS-279:

The original design showed twoiM4x15 horizontal beams supported by fillet welds from the web of a'W14xl84 beam.

A 8509 variable spring hanger was supported from the 'end of each M4x15.

The as-built condition shows both M4x15 beams mounted on top of the W14xl84 beam,',and.

one,,of~'the M4xl5 beams reoriented in the horizontal plane,and welshed with differ'ent weld details.

A 8508 variable spring hanger<wa's'rovided.(h'as'essor load capability than

$ 509).

H 1f The inspector noted 'that the.,li.censee, corre'spondence-.to~the NRC contractor (NS-L-02-RMW-81-036) did, not'"alert'hejcoDtractor; to-the'general discrepancies in the as-built conditions of, 'pipirig systems.

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Roe representative stated that it was under'stood,'that,:the-HNP.-. 2'project would provide whatever information was -available at'this tirpe.

'he inspector advised the,NRC,liceps-ing.project~m'anager of this matter on September 28, 1981",,',

No ";further';insp'ecto'r ac'tjon i',anticipated and the matter is considered =closed.

l 15.

Corres ondence Action Item Control During the NRC team inspection of Septepber 1, the team leader requested the resident inspector to review the--WPPSS correspondence control provisions.

The inspector reviewed the Project Management Instruction manual to ascertain applicable instructions and selected PMI-12-3, PMI (2. 1, PMI-2-12, and PMI-2.2 as being most applicable to control of action items.

The cler k who is responsible for tracking correspondence'or Burns and Roe was also interviewed.

The inspector interviewed the clerk who is responsible for tracking actions on vendor submittals.

She uses a Transmittal Control Log (TCL) as the computerized tracking system.

It provides the following two reports where items appear when they are at least 21 days past due:

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.of d'ocuments previously submitted -by contr actors, but returned unapproved or approved as noted.

TCL-B identifies submittals which have not yet been acted upon by either. Burns Il Roe, WPPSS, or Bechtel.

These control documents appear to assure that transmittal type action items will be resolved as a condition of close-out of the applicable contracts.

However, a

WPPSS Corrective Action Request, outstanding since its February 25, 1981 issuance,'dentifies that there are items which date as far back as 1973 without further action.

As of September 3,

1981 the gA organization has been unable to obtain an acceptable corrective plan from the construction management or document control organizations.

Pi e Whi Restraint Re airs and Refabrication The inspector reviewed records, plans, and procedures, and interviewed personnel relative to corrective actions for questionable pipe whip restraints.

He observed nondestructive testing in-progress for one such pipe whip restraint (PWR-3-2), in the Bechtel site shop.

The inspector considered these activities relative to the corrective action plans discussed in the WPPSS letters to NRC dated December 10, 1979 and February 1,

1980, as acknowledged by the NRC work release letter to WPPSS dated February 8, 1980.

The inspector also considered the WPPSS July 11, 1980 reply to the NRC Notice of Violation of June 17, 1980.

Several of the replies in the WPPSS July 11 letter referred to a planned WPPSS reply to the NRC annual appraisal, as the source of information for "the corrective actions planned to be taken to correct the underlying cause of the noncompliance" (items II.A.1,2,3, and 4, and IIB.1,2,3 and 4, of the NRC Notice of Violation).

The referenced submittal was never provided, (it is noted that NRC did not require a written response to the appraisal).

This submittal was stated to be in addition to the required WPPSS reply to the Notice of Violation, and the July 17, 1980 reply to the NRC's

CFR 50.54(f) inquiry.

Although corrective measures have been taken to repair or refabricate the pipe whip restraints, including quality assurance measures, it is not clear that a specific effort was made to define the underlying cause of the previous noncompliances to prevent recurrences.,

This matter is unresolved pending the WPPSS clarification of the public record in this regard.

(397/81-18-07)

Some pipe whip restraints those with electroslag welds) will be refabricated by an off-site contractor Huico), under contract to WBG, using material supplied by WPPSS.

The supplier's procedures have been reviewed by WBG and a

WBG quality assurance engineer has been assigned to the supplier's shop to assure proper implementation of his fabrication gA program.

The contractor will also have his own gC inspectors.

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New specification section 5E and 17E have been issued for the work ( P ED-215-CS-A367, A4545).

The remaining pipe whip restraints quill, be'- reinspected;by Bechtel and repaired on-site by Bechtel; Each:.restraint. wi 1,l b'e subject to a shop receiving inspect'ion,-'which 'iincludes',ultrasonic and magnetic particle nondestructive~testing.-,'Be'chte$

I and.Burns E

Roe 'approved nondestructive examination.".,and welding procedures wil,l'e.used.

NDE personnel and welder qua1ifications,wil,l,',be.,'monitorel-by,Bechtel.

New specification sections '5E,',and 17D have,been'issued",for the work (PED-215-CS-A367 and A545-),.;

For the on-site repairs,~Beche'el p'l,ans to!;review, each, outstanding NCR (nonconformance report),',foe'ach, r'es'dr~aint'nd,include the corrective actions in the repair effoit".

The responsible Bee/tel engineer has compiled a planning matrix which identifies each such outstanding NCR and each new Bechtel'"NCR generated as a result~of'the,Bechtel shop receiving inspections<.

The engineer had rev,iewed each existing NCR and had categorized each as to its topic.

Revi'ew of this grouping and interview of the engineer revealed-an absence of the materials certification related items which appear, in the

"ITEMS OF CONCERN FOR PWR" tabulation of Section II of the WPPSS February 1,

1980 letter to the NRC.

Since the NCRs represent the sole reference point for the Bechtel engineer for previously identified discrepancies, the inspector

,

requested object'ive evidence that all of the known discrepancies are documented on the existing NCRs.

The licensee acknowledged the question, and committed to provide such information.

This matter is unresolved pending review of the information.

(397/81-18-08)

Item 15 of the "PIPE WHIP RESTRAINT PUNCH LIST", attached to the WPPSS December 10, 1979 letter to NRC, noted a problem in that "spot RT on UT" is suggested by the Code (AWS).

Such RT is not required by the new,,specifications or procedures.

This matter is unresolved pending review of the WPPSS position on the Code recormendation.

(397/81-18-09)

The WPPSS December 10, 1979 letter to NRC stated that a procedure would be provided to the NRC inspectors for review, describing, actions and approvals necessary to release any restraints from the stop work order.

Such a procedure has been developed for the Bechtel on-site repairs (SWP/P-P-5),

and for the WBG contracted off-site refabrication (WBG-BEC-215-81-0625).

For the on-site repairs, the procedure does not identify the sequence of actions necessary to clear the existing NCR's as related to additional repair work needed.

Also, the specification change (PED-A545 part 3.4.2. 1) requires case-by-case referral to the Engineer (Burns 5 Roe) of each pipe whip restraint repair for evaluation and recommendations for stress relief heat treatment.

- These actions and approvals are not addressed in the.Bechtel summary control procedure, nor are they included in the informal work flow diagrams presented to the inspector as the Bechtel detailed basis for administering the work.

(These diagrams had been prepared by Bechtel at the insistence

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This matter is unresolved pending review of the effectiveness of the work controls and conduct of the work.

(397/81-18-10)

The inspector observed the Bestco NDE technicians perform magnetic particle examination of restraint 83-2.

He reviewed the applicable procedure and interviewed the technicians relative to the ultrasonic testing.

It was ascertained that a straight-beam check for laminations is prescribed and is being performed (this was a previously identified discrepancy in the Leckenby work, per item 13 of the December 10, 1979

"PIPE WHIP RESTRAINT PUNCH LIST").

The inspector did not review the procedures in detail, but ascertained that they had been reviewed and approved by Bechtel.

Pi e Whi Su ort Evaluations J,

During the licensee review of the pipe whip restraint documentation, the licensee recognized that similar weld deficiencies may exist in similar structures fabricated by the contractor (Leckenby).

The licensee initiated a study of 1) pipe whip support brackets, 2) pipe whip support girders and columns,

pipe penetration doors and 4) stabilizer trusses and mounts.

Problems of unqualified welder', questionable inspector qualifications, and use,:of"unapproved procedures were sought.

The licensee has documented the results of this stud/

as, a pending addenda to the final engineering evaluatio'n report 'on the sacrificial shield wall which was previousl'y submitted to,NR6.'~

The inspector revieqed the scope,and results of,. the above study.

It included well organized.dociimehtation reviews,and,no'ndestructive testing of materials.

The licensee defined 35 weld maps and corresponding engineering drawings which'-t$ e Engineer, hade reviewed-;,and concurred in as the def ined scope of. wor k.

The results of the evaluation documented the discrepancies on nonconformance reports which will'e evaluated and dispositioned by the'Engineer.

Of 2414 welds, 1307 had improper traceability, 114 were rejected by visual re-inspection, and 334 were inaccessible. 'he inspector reviewed the criteria used for classification as inaccessible and did not identify any discrepancies.

The inspector noted -that the licensee's program associated with the sacrificial shield wall had considered the generic aspect of material from this supplier and had taken the appropriate action to investigate this matter.

The inspector identified no items of noncompliance relative to the licensee's effort.

Licensee Action on Previous Ins ection Findin s

The WPPSS Program Director has assigned senior management personnel to assist the Bechtel quality assurance engineer in evaluating past WPPSS commitments made in response to NRC inspection findings.

The effort is focused on identifying continuing commitments, i.e. those

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The intent was to incorporate these into a separate specification to Bechtel, but the current plan involves revising existing contract specifications to incorporate the requirements.

Also included in this effort is the re-evaluation of special requirements checklists which were used as the basis for May 1981 NRC closeout of several inspection findings.

During the current report period, the inspector reviewed data which supported the following conclusions relative to licensee action on previous inspection findings:

a.

Closed Fo l 1 owu Itern 397/79-16-01)

Sacrificial Shield Wall Concrete Void Repair:

The matter oF concrete void discovery and repair plans were previously reviewed and documented in inspection reports 50-397/78-10, 78-11, 79-08 and 81-03.

The inspector examined the licensee actions to further assess the concrete voids and preparations for filling of the voids.

He considered the technique qualification and prototype plans described to NRC in the August 1, 1980 transmittal of the Engineering Evaluation of the Sacrificial Shield Wall (NRC Concern 82).

Some minor departures from the plan were reviewed.

These appeared reasonable and prudent.

The licensee stated that these would be defined to NRC via a planned futur e update of the above noted report.

The licensee had Muenow Associates perform a microseismic test of the areas in the reactor active core region.

These sonic tests were validated by drilling 1/4-inch holes at the prescribed locations, and impacting the concrete through the hole to assure

'oundness.

There were 177 locations examined sonically.

I Initial qualification of the process included drilling holes at ten locations each day,'epresenting the approximate 30 holes per day tested soni'cally.

Most of'~the holes each day were made at locations tha't the contractor declared were free of voids.

The initial tests'ncluded, some data,points which raised questions regarding the,accuracy;of the" process; however, further development of technique show'ed that care, needed 'on)y, t'O'e,exercised to assure that the hammer.

impulse,and the transduce'r be'onfined to the same SSW compartm'ent,for",,'each test.

'A slight, change in the test procedure appeared to,resolve the,,problem.

Appropriately, the initial test data wa's dis'regarded,,and the areas retested.

The licensee appeared to have adequately qualified the process.

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During the testing activities, the equipment was calibrated twice each day by checking the wall location at plate number A655.

The individual performing the sonic tests owned the company and had used the process at several other nuclear plants, although on bare concrete surfaces only.

The licensee representatives evaluating and performing mockup work were engineers from Burns and Roe.

They demonstrated adequate familiarity were with the report to NRC, the known past concrete placement practices and characteristics, and the structural significance of the work.

No attempt has been made to remove any steel plates to observe surface voids since the licensee believes that the column flanges will mask the access to any voids in the upper corners of each compartment.

The licensee has instead relied upon drilled 1/4

'nch holes and fibre optics.,

P For placement of the shield material the licensee has designed mockup tests of compartments with concrete and voids.

A technique of drawing a vacuum and fillingwith NS-1 material is planned that has been tried, using a concr'ete,grout mix initially.

Further tests are planned.

<<,The engineer,<<described appropri ate plans to include attempts to','inject.the. NS-1',',material:"through drilled holes to simulated voids at.the faV-end(back) of the'acrificial shield wal 1.

No items of noncompliance weredent~fied',I',".and,'the.

program changes did not appear'. to represent',any's'ignificant

"departur'e from the prior plans presented to,the,NRC..

Closed Noncom li'ance'- 397/80'-04-,02

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The contractor (Leckenby) failed to'pr'ovide-'approved NDE procedures prior to start, of work'.

See paragraph 16 of,tkis'report for the general corrective action program, which inclu'des total reinspection "of"'ach pipe whip restraint, including NDE prior to.,and after repairs or refabrication.

Closed Noncom liance 397/80-04-08 The contractor (Leckenby) quality records failed to accurately identify the visual inspection personne I ~

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-19-See paragraph 16 of this report for the general corrective action program, which includes total reinspection of each pipe whip restraint, both before and after repair, or after refabrication.

d.

Closed Noncom liance 397/80-04-09 The contractor (Leckenby) allowed Uncertified personnel to perform NDE of pipe whip restraints.

See paragraph 16 of this report for the general corrective action program, which includes total reinspection of each pipe whip restraint.

I e.

Closed Noncom liance 397/80-04-13 The contractor (Leckenby) failed to perform straight beam ultrasonic testing for laminations.

See paragraph 16 of this report for the general corrective action program, which includes total reinspection of the pipe whip restraints by ultrasonic testing, using procedures which do specify the straight beam examination.

Closed Noncom liance 397/80-04-17 The contr actor (Leckenby) pipe whip restraint quality records contain inconsistencies and do not accurately reflect quality activities.

g, See paragraph 16 of this report for the general corrective action program, which includes total reinspection of each pipe whip restraint.

Also, par agraph 16 identifies a

new unresolved item regarding translation of materialsi discrepancies into the current corrective action program.

Except for that aspect, which will bddressed separately, this item is closed.

Closed Noncom liance 397/80-04-18 The contractor (Leckenby) pipewhiprestraint,quality records do not correctly identify the NDEo,ins~ectorsc See paragraph 16 of this report for the general'corrective action program, which '.i'ri'eludes, totsa'1,,'einspection

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A Closed Noncom liance 397/80'-'04-19 A contractor (Leckenby) pipe whip restraint quality record was signed and dated by an individual prior to his employment date.

1I See paragraph 16 of this'report for'he general corrective action program, which includes total reinspection of each pipe whip restraint.

Closed Noncom,l"i,ance, 397/80-'04-'05 The contractor.;(L'eckehby)"had'not'enerate'd formal, procedures to control heat"-straightenin'g of.,pjpe ~hip,',r'estraints.

Paragraph 16 of this report di'scysses the,.general corrective action program, which incl'udes refabricat'ion,'and repair~ o,pipe. whip restraints.

The procedures for'"such'repa'ir/<refabrication'nclude provisions which prohibit heat straightening. 'he, licensee'"has submitted a technical analysis'f,the'impact of.,heat.straightening, and an accept-as-is'ational,, in a letter to-NRC dated September 30, 1981.

This item has beep evaluated by the!Region and is considered to be closed.

19.

Unresolved Items Unresolved items are matters about which more <information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.

Unresolved items identified during this inspection are discussed in paragraphs 6, 8a, 9, 10, 11, 13, and 16.

20.

Mana ement Meetin s

The inspector met with licensee management on October 2, 1981 to discuss his inspection findings and summarize his activities during this report period.

Attendees at this meeting are identified in paragraph 1 of

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