IR 05000397/1981025
| ML20040H542 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/29/1982 |
| From: | Dodds R, Feil R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20040H540 | List: |
| References | |
| 50-397-81-25, NUDOCS 8202180364 | |
| Download: ML20040H542 (10) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION CFFICE OF INSPECTION AND ENFORCEMENT
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REGION V
Report No. 50-397/81-25
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Docket No.
50-397 License No. CPPR-93 Safeguards Group Licensee:
Washington Public Power Supply System P.
O.
Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project No. 2 (WNP-2)
Inspection at:
WNP-2 Site, Benton County, Washington Inspection conducted:
December, 1981 Inspectors:
//,2/ PL em R.'A.
Fdil, Senlof Resident Inspector
/ Dat'e Signed Date Signed Date Signed Approved By:
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R.
T.
Dodds, Chief
[ late ' Signed Reactor Construction Projects Section 2 Summary:
Inspection during December 1981 (Report No. 50-397/81-25 Areas Inspected: Routine, unannounced inspection of licensee and contractor activities to re-evaluate and improve detailed work methods.
The inspection involved 64 inspector-hours on-site by the NRC resident inspector.
Results: No items of noncompliance or deviations were identified.
8202180364 820204 PDR ADOCK 05000397 G
PDR RV Form 219 (2)
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DETAILS 1.
Persons Contacted Washington Public Power Supply System (WPPSS)
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S.
Carlisle, Deputy Program Director H.
A.
Crisp, Manager Construction e,
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B.
Dunning, Acting Manager, Systems Completion J.
R.
Honekamp, Technical Specialist
- R.
T.
Johnson, Manager, Quality Assurance-W.
G.
Keltner, Assistant Manager, Construction
- R.
L.
Knawa, Manager, QUP - Documentation R.
G.
Matlock, Program Director
- R.
M.
Nelson, Licensing Manager Bechtel Power Corporation (BPC)
- D.
K.
Cosgrove, QAE
- M.
J.
Jacobson, QA Manager D.
R.
Johnson, Manager of Quality J.
H.
Stauffer, Large Pipe Engineer WSH/Boecon/GERI/(WBG)
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Bowen, QC Procurement Supervisor M.
Clinton, QA Manager D.
Gallik, Systems Completion Function. Manager
- M.
Hayes, QAE Task Force Supervisor M.
Houck, Technical Engineering Coordinator R.
Scott, Documentation Manager P.
Webster, (Former QA Manager)
R.
Walters, System Completion Documentation Manager
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Boeiny, Engineering and-Construction Company (Boecen)
M.
P.
Thompson, Director of-Quality Ar.surance
- Denotes those present at monthly management meeting.
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The inspector z' Iso conferred with other licensee and contractor personnel during the course'of the inspection period.
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2.
General The inspector was informed that the following WBG personnel changes, had been made.
Mr. David Gallick replaced Mr. Mike Houck as Systems Completion Function Manage i
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Mr. Menzo Clinton ih replacedkr. Paul' Webster as Quality Assurance Manager.
1The - inspector attended, several: 11' cense / contractor management meetings in the course'of the inspection.
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Facility Tours-
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The inspector. observed work _ activities in-progress, completed work and plantistatus in several areas of the plant during r
general inspections of;the' plant.
The inspector examined work for any obvious defects or noncompliance with regulatory requirements or license conditions.
Particular note was taken of the presence of quality control inspectors and quality con-trol evidence such as inspection records, material identifica-tion, nonconforming material" identification, housekeeping and equipment preservation.
No items of noncompliance or deviations were identified.
4.
Licensee Action on Previous Inspection Items-a (Closed) Unresolved Item 50-397/81-18/09 Spot radiography (RT) for pipe whip restraints (PWR)
Item 15 of the " PIPE WHIP RESTRAINT PUNCH LIST", attached to'the WPPSS December 10, 1979 letter to the NRC, noted a problem in that "... spot RT on UT..." was suggested by the AWS Code.
Such RT was not required by the new specification or procedures.
The-WPPSS position on the Code recommendation was that-spot RT was suggested by the AWS Code and was not a re-quirement.
Since the physical configuration of the PWR's do not lend themselves to RT, the licensee will not be imposing spot RT into the PWR procedures and. specifications.
This item is considered closed, b.
(Closed) Unresolved Item 50-397/81-09/01 - Definition of quality assurance controls for Quality Class II/ Seismic Category 1 work.
The licensee has reviewed contracts of contractors who may have done work or are doing work subject to Quality Class II/ Seismic Category 1 criteria.
These contractors /
contracts include Peter Kewit & Sons (PKS) (206A), WSH/
Boecon/GERI (WBG) (215), Waldinger Corporation (216),
Sentry Automatic Sprinkler Company (217). Fischbach/ Lord
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-3-Electric Company (218), Johnson Controls (220) and Lord
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Electric Company (228).. As a result of the review, items which were classified.as Quality Class II/ Seismic Category 1_were down graded to' Quality Class II/ Seismic
Category II..
This item,1~stconsidered closed'.
c.
(Closed) Unrbsolved Item'50-397/81-17/02 - Revision of Project Management Instruction to delete inappropriate references to~ Burns and Roe. Quality Assurance The inspector reviewed WNP-2 Project Instruction PMI 4-4.1, Revision 3~,
" Preparation of Nonconformance Reports" and verified-that inappropriate re'ferences to Burns and Roe Quality Assurance have been deleted.
WNP-2 Project Instruction, PMI 4-9, Revision 0,
" Fire Protection Quality Assurance Program Requirements" will not be revised.
The instruction describes Burns and Roe responsibility for the design and procurement of the fire protection system.
Also, the Burns and Roe quality control organization is responsible for implement-ing surveillance inspections of vendors and contractors performing work on fire protection systems.
The instruc-tion properly reflects FSAR quality program requirements for fire protection as identified in Amendment 17 dated July 1981 and the references to the Burns and Roe group in the quality assurance instruction appear to be appropriate.
This item is considered closed.
5.
Allegation:
Alteration of Documents The NRC received an allegation concerning the alteration of documents which are retained in the quality assurance vault at WBG.
Documents which had been accepted by the WBG QC re-viewing inspection group were found to contain corrections made with " Liquid Paper" without any notation or clarification.
The Acceptance Test Data Summary Sheet for Purchase Order 215-1534Q, Customer Tag SW-TI-lla ATP Document 1775-825 for thermowells had been changed by the use of " Liquid Paper" on the tag number (SW-TI-11a).
This information was also given to WBG QA manage-ment by the alleger.
The inspector reviewed the document in question and verified that the document had been altered by the use of " Liquid Paper".
WBG QA personnel re-reviewed the con-tract procurement package and determined that additional documents had been altered in the same manner.
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WBG.sent an auditor.to the supplier of the thermowells'in question', Hy-Cal Engineering.- Copies of. questionable documents
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comparison between documents received'by were taken to make a
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WBG and those3 retained bylHy-Cal.. ;The documents matched and
'the auditor' co,ncluded ithat. thel changes had been made by the vendor: prior to documentjtransmittal..The Hy-Cal quality
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assurance' manager informed"the-WBG auditor that the~ changes in the doc'uments' wereim'ade.;af te'r..the QA manager had f ound errors
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in the doenments and reques f ed ;tha't they be corrected prior to
.The QA manager stated that he i
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i had f ailed -to' 're t awl thei correc ted documents after the typist
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had used' white out, to make the corrections.
He stated that new
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original documents would be sent,to.WBG. The inspector verified that 62 new. original Acceptance T e's't Data Sheets were received from Hy-Cal Engineering. to replace the altered data sheets in the WBG vault.
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The inspector discussed the actions taken by WBG to resolve ~
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.the issue of altered documents with,the alleger.
The alleger
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problem of the altered test. data sheets.
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6.
Procurement Document Review
a.
On November 25, 1980 Corrective Action Report (CAR) 192
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was - initiated.
The CAR described deficiencies found i
during an initial review performed by WBG on purchase requistions, purchase orders and vendor documentation.
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The documents were not in compliance with contractural requirements of 2808-215 contract.
The signficant find-
ings as described by CAR 192, included the following:
(1)
AP&E, Borg Warner, NPS, Seattle Industrial, Pybus,
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Signal Hill and NIX have all been identified having missing or incomplete documentation.
as In most cases, action to review-the data packages was started, but never completed.
(2)
WBG purchase requisitions and purchase orders do not adequately identify the applicable codes, documentation requirements, etc.
(3)
The procurement discrepancy reports identify deficiencies in the areas of Project Specifi-
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cation, P.O./ Contracts, WBG Procedures, ANSI /
ASME Codes, Receiving, and Vendor Procedures.
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(4)
Purchase requisi;tions;do not reflect all the 3 requirements imposedsby?the 215 Contract
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(Specifications.
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locorrect'ASME' Code editions were specified on.
requ!sitions and' purchase ~ orders.
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(6) ' Applicable contract: specification sections were described on purchase requisitions or purchase orders.
(7)
Insufficient Q.A. documentation requirements were listed on the purchase order (P.O.)
(8)
Authorized Vender List data was incorrect.
(9)
Subcontracts did not reflect all the applicable contract specification sections.
(10)
Subcontractors procedures were not submitted for WBG review.
Subsequently. CAR's 192-1, 192-2 and 192-3 superceded CAR 192.
These CAR's divided the problems into the specific areas defined by the contract quality assurance requirements.
b.
WBG Management designated a Procurement Documen-tation Review team comprised of representatives from Quality Assurance, Engineering and Procurement departments.
This team is responsible for review and implementing action to correct all nonconforming WBG Quality Class I,
II, and G procurements initiated prior to June 2, 1980, with the objective of provid-ing documentation in compliance with Appendix B of 10 CFR 50, ANSI N45.2, ASME Section III, and add-itional requirements described in the 2808-215 Contract.
'The Procurement Documentation Review Team submitted to the Quality Assurance Manager for review and approval the Corrective Plan to implement in re-view of WBG procurement documents and vendor sub-mittal data initiated prior to June 2, 1980.
The Corrective Plan provides for:
(1)
Assuring obj ective evidence exists that purchased material, equipment, and services, whether pur-chased directly or through Contractors, conforms to the procurement document, and that procure-ment documents specify all requirements of the 2808-215 Contract.
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(2)
Assuring through quality reviews that a thorough,
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complete technical review.and approval of, pro-curement doduments and vendor' submittal data
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has beenl accomplished.
This shall be accom.
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plished with the aid of the following controlled documents:
(a)
Pr'ocurement Documentation Review' Engineering
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Checklist
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(6)" Documentation Deficiency List (DDL)
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Procurement Documentation Review T r a'n s m i i t a l,.
(d)[ Purchase,0r. der' dog, s
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(3) rAssuring.that_ procurement documentation review
[ packages are.not-closed out or vaulted until I al1#the above requirements have been complied with.
IR/NCRs,init,iat(d against a' procurement shall be closed prior to' vaulting that pro-
c'u r e m e n t-package.
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c.
All WBG Project Departments are: supporting this. review activity,"as required to its conclusion.
All purchase documents initiated prior to June 2., 1980 whether open or vaulted, are supposed to be reviewed in accordance l
with this Corrective Action Plan.
To support the review, personnel involved in procurement activity review were trained to the latest revisions of applicable and QA procedures.
The Engineering Manager-and Project Quality Assurance Manager are responsible to-assure that their respective departments are complying with-contract 2808-215 quality assurance requirements by' con-ducting procedural and completed package reviews.
WBG initiated Work Procedure (WP) 788, Procurement Document Review, dated September 30, 1981, to provide detailed in-struction for (1) the review of documentation; (2).identifi-cation, and resolution of problems; and (3) acceptance of materials, equipment and/or subcontracts procured by WBG prior to June 2, 1980.
This procedure also established and implemented the Corrective Action Plan to resolve the discrepancies and concerns reported on CAR's-192-1, 192-2 and 192-3 and also provided for interface with systems completion priorities for verification of heat records.
The control and filing of quality assurance records used in - the review process was in accordance with Quality Assurance Procedure (QAP) 410, Revision 1 dated October 20, 1980.
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The inspector selected a procurement package for. review'to determine.if all requirements of the review process were being met.
The package was Purchase Order No.. 215-153Q to Hy-Cal Engineering.
(This package was selected be-cause of the allegation regarding SW-TI-lla thermowell.
' documentation alteration.).The purchase order was for 175 test thermowells, 23 protection:thermowells for temperature switches and 60 protection thermowells for indicating thermometers.
The package consisted of material certificates,
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cleaning certificates, acceptance. test data reports for hydrostatic testing and visual inspect. ion, specifi-cations, documentation deficiency list, statements of conformity and certification of raw material.
The inspector ascertained after a review of the package and the dispostion of the documents that the documenta-tion review process by WBG appeared to be deficient.
These deficiencies included, but were not limited to the following:
(1)
Some activities.being performed by the review teams were not. covered by procedures.
The review teams were working to Work Procedure 788, Procurement Document Review.and Quality Assurance Procedure 410, Documentation and Records Control.
These Procedures did not cover all activities of the review and trans-mittal process.
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Procedures were'not being followed in some instances (i.e.,
assembly of procurement' pack-ages and transmittal.of documents to the QA vault).
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Control of documentsLin.t'he review package was questionable.
There~was no index-or item-ization of documents within,the packages,
.As t h e 'p e'r s o n's-d o in g the:revie'w may a result,.if they have;all the-required documen-
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not know tation needed for a comp'le ted 'r eview..Further,
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persons not associated with the review had access to the r'eviewedfpackages.
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(4)
The documents tr'ansmitted b'y material control to Bechtel receiving were not necessarily those documents which had been reviewed in the review process.
In order to. satisfy Rechtel receiving, materia'l control persons copied
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the-most legiblefcopy rather than copy the f.
documentLwhich had been reviewed.
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no guarantee that -the review process' entailed f
reviewing copies.of the original documents themselves.
This. mechanism did not provide for,det'ermining ifra document.may have been altered by " Liquid Paper" since;the-copy does no't show marks of " Liquid Paper".use.
'(This is the, basis for thez allegation' addressed in paragraph 5,)
The inspector also reviewed. procurement packages'for Purchase Orders 215-38220Q & 215-1534Q,,Hy-Cal Engineer-ing.
The packages contained pen and ink-changes to some document items without notations to.the changes as re-quired by ANSI N H5.2.9-1974, Paragraph 3.2.6.
.The inspector was informed that the review teams did not review the documents for changes since the review teams were only responsible for. verifying the' original data of the specification / purchase order and the heat numbers of the components.
The licensee stated that he would investigate and determine what actions should be taken, if any.
The inspector was informed that action was being taken to resolve these deficiencies as follows:
(a)
Work Procedure 787, Transfer of Materials Equipment and Supplies to Bechtel, was in the process of being published.
The procedure will cover activities such as preoperation and assembly of review packages and transmittal of documents to the Bechtel QC receiving inspection group.
WP 787 covers activities not previously addressed in QAP 410.
However, the'
depth of review of the procurement packages is still in question in light of the pen and ink changes found in other packages reviewed by the inspector (P.O. 215-3822Q, Liberty Equipment)
(P.O. 215-1532Q, P.O. 215-1533Q and P.O.
215-1534Q, Hy-Cal Engineering).
(b)
The Procurement Document storage area referred to as the Engineering Vault is now-a controlled area.
A wire barrier has been constructed around the l
record storage area.
Forms are being used to control
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the movement of documents to and from the storage area.
Additional training and instruction was given to personnel in the control of reviewed documents.
(c)
QAP 410 has been revised to include a requirement of a " document reviewed" stamp on each page which has been reviewed prior to its, transmittal to' Bech tel
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QC receiving will be re-reviewed in accordance with the new procedure.
The re-review was expected to be complet'ed by February 28,-1982.
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This item is unresolved pending verification of actions to resolve the identified. deficiencies. (50-397/81-25/01)
The inspector reviewed the documents in'the Bechtel QC Receiving office.regarding documentation for temperature well SW 7
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These-docu'en'ts.were requested by Field m
Material Request Form No. 541'Rev.
O, dated September 30, 1981.
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The quality documentation required. included material test reports, all supporting-documentation and a certi-ficate of compliance.
The package contained copies of the requested documentation.
Subsequently, the inspector located Field Material Request Form No. 541, Rev. 1 dated October 15,.1981.which corrected the FMR No. 541, Rev. O specification notation.
In addition, the ASME code data reports and nonconformance reports,1f any,were requested in FMR, Rev.
1.
FMR Rev. 2 was issued October 22, 1981.
It revised FMR, No. 541, Rev. O by adding temperature well for code responsibility transfer.
The inspector informed the licensee that he was unable to determine why the documentation package sent in re-ponse to FMR No. 541, Rev.
O, and supposedly supporting the installation of thermowell SWT-T1-1A, did not reflect the additional requirements of Rev. 1 and Rev. 2 of FMR No. 541.
Tnt item had been installed into the service water systems.
The inspector also pointed out the discrepancy in FMR No 541, Rev. 1 which requested the ASME Code Data Report.
Since the thermowell was installed by a subcontractor, Associated Piping and Engineering Corp., a ASME Code Data Report for thermowell SW-T1-1A was not required.
The licensee and Bechtel are reviewing the FMR process in an attempt to preclude discrepancies and to provide for a more afficient mechanism to insure that documentation requested by a FMR reflects all the documentation needed to support the fabrication, installation and inspection of an item received by Bechtel QC receiving from WBG or the documentation of an item previously installed by the constructor.
7.
Status of Thermowell SW-TI-llA The inspector observed that thermowell SW-TI-llA had been removed from a spool piece in the service water cooling
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-10-system for diesel generator lA.
The inspector noted that a ridge on the thermowell had been ground down in the removal process.
The thermowell was subsequently replaced in spool piece SW-303-4 which is a part of SW-303-4.6, diesel generator service water cooling.
The inspector expressed concern to the licensee that the replaced thermowell may not meet the same design requirements as the original thermowell since some metal had been removed.
This item remains unresolved pending verification that the thermowell meets the original design requirements.
(50-397/
81-25/02)
8.
Unresolved Items
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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 and 7.
9.
Management Meetings The inspector met with the WPPSS site QA manager on December 30, 1981, to discuss status of his inspection efforts and to re-o ceive a status report of principal WPPSS activities.