IR 05000397/1982012

IE Insp Rept 50-397/82-12 on 820501-31.No Noncompliance Noted.Major Areas Inspected:Contractor Activities & Investigation of Allegations Re Processing of Nonconformance Repts & Insp of Fire Protection Sys

ML20054N046
Person / Time
Site:	Columbia
Issue date:	07/01/1982
From:	Dodd R, Dodds R, Elin J, Feil R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20054N042	List: IR 05000397/1982012 ML20054N041
References
50-397-82-12, NUDOCS 8207150299
Download: ML20054N046 (12)

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U.S. NUCLEAR REGULATORY COMMTSSION

REGION V

Report No. 50-397/82-12 Docket No. 50-397 License No. CPPR-93 Safeguards Group Licensee: Washington Public Power Supply System P. Box 968 Richland, Washington 99352 Facility Name: Washington Nuclear Project No. 2 (WNP-2)

Inspection at: WNP-2 Site, Benton County, Washington Inspection conducted: .May 1982 Inspectors:

Rf/A. Feil, U b(

nior Resident Inspector

[.,- 3d'M1 Date Signed Z fd_ (- > ~ .5 0 ~ WL

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F/ L. Toth' Senior Resident Inspector Date Signed E 6,- 3d ~ ? L f. O . .Elin, Reactor Inspector Date Signed Approved By: bdC h 7 !I/8 R. T. Dodds, chief '

Date signed Reactor Construction Projects Section 2 Summary:

Inspection during May 1982 (Report No. 50-397/82-12)

Areas Inspected: Non-routine, unannounced inspection of licensee and contractor activities and investigation of allegations. The in-spection involved 188 inspector hours on-site by 2 NRC resident inspectors and 1 region based inspecto Results: No items of noncompliance or deviations were identifie PDR 0 ADOCK 05000397 PDR RV Form 219 (2) ,

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DETAILS Persons-Contacted .

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Washington Public Power Supply System (WPPSS)

• C S. Cartisle, Deputy Program Manager H. A. Crisp, Project Construction Manager

'*L. C. Floyd, Quality Assurance Engineer

• R. T. Johnson, Project Quality Assurance Manager W. G. Keltner, Assistant Project Construction Manager

• R. M. Nelson, Licensing Proj ect Manager Bechtel Power Corporation (BPC)

D. Brons, Quality Control Inspector L. Burch, Quality Control Field Supervisor G. Chapman, Quality Control Inspector R. Coomes, Superintendent, Lay down Area

• R. E. Davis, Quality Assurance Engineer

• B. Gatewood, Project Quality Assurance Manager

• C D. Headrick, Project Construction Quality Control Manager E. Horn, Superintendent, Fabrication Shop D. R. Johnson, Manager of Quality F. Pender, Tool Calibration B. Raymond, Quality Control Receiving Supervisor Shaffer, Quality Control Inspector P. Steeb, Assistant Construction Quality Control Manager Burns and Roe Incorporated (BRI)

• A. T. Luksie, Proj ect Licensing Manager L. Noble, Civil Engineer J. Mahoney, Hanger Engineer

• R. P. Sabol, Quality Assurance Engineer

• Denotes those present at monthly management meetin The inspectors also conferred with other licensee and contractor personnel during the course of the inspection period. The resident inspector attended several management meetings during the inspection perio . Investigation of Allegations The inspector was informed of nine (9) allegations. The allegations were investigated by resident inspectors and a Region V inspecto None of the allegations were substantiated although two un-resolved issues were identified related to the allegation To

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-2-be considered substantiated; a finding must be (1) true, (2) in violation of regulatory requirements, and (3) must not have been previously identified as being properly handled by the licensees'

quality progra Allegation: Some Nonconformance Reports (NCRs) are not processe "A NCR identifying an overheating condition on a pipe whip restraint was submitted by a quality control inspector to his superviso Initially the Assistant Project Construction Quality Control Engineer (Ass ' PCQCE) was going to validate the NC Subse date the NCR." quently the Ass't. PCQCE decided not to vali-Finding: This allegation was not substantiated. Although program changes will be made to prevent misunderstanding NCR dispositions (1) Procedure Requirements:

The BPC WNP-2 Construction Quality Control Manual stated in paragraph 3.1.1,Section IV; "A noncon-formance is defined as a deficiency in characteristic, documentation or procedure which renders the quality of an item unacceptable or indeterminate with respect to the program criteria. Examples of nonconformances include physical defects, test failures, incorrect or inadequate documentation, and deviations from prescribed 1 processing, inspection or test procedures."

(2) Preparation of NCR's: .

" Nonconforming items may be identified and reported to Construction Quality Control by anyone in the Bechtel organization. However, the validation of formal non-conformance reports (NCR's) shall be the responsibility of the Project Construction Quality Control Engineer."

"NCR's shall be prepared in accordance with detailed

, instruction, and a standard form for recording the required information."

"The NCR shall be accurately and concisely written after consultation with the interested parties to ensure that the oiscrepancy is correctly described, the appropriate program criteria are referenced, and that sufficient data is provided.to facilitate a proper and complete disposition for resolving the nonconformance." .

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(3) Validation of NCR's:

Prior to validation of the NCR, the originator shall review it for conformance with the requirements of The Bechtel Procedure described abov "The NCR shall be' validated by the Project' Construction Quality Control Engineer after consultation with the Project Field Engineer for clarity of technical data described in the report."

BPC Procedure SWP/P-G-7, Field Engineering Processing of Bechtel - Generated Nonconformance Reports, Rev. 1 dated July 27, 1981 states in part; " Nonconforming items may be identified and reported to Construction Quality Con-trol by anyone in the Bechtel organization. Validation of formal nonconformance reports (NCR's) is the responsi-bility of the PCQCE."

The inspector conferred with BPC and licensee personnel about the specific NCR sited in the allegation. The NCR was not processed because (1) the temperature recorded in the chart was in error because of a broken thermcouple i and (2) the temperature was taken with a pyrometer which indicated the temperature was 248 F. This temperature is within the temperature boundary requirements of 225 - 350 as prescribed by PED 215 - W B030, and was done in accor-dance with Quality Control Instruction (QCI) 14631/W-10 To preclude further allegations and misunderstandings on NCR processing and to insure that all safety issues are identified, BPC has issued Administrative Instruction

No. 15; Control of NCR's. The instruction prescribes the methodology for submitting a NCR by anyone with BPC. All NCR's initiated will be assigned a number by the QC vaul All NCR's will be dispositioned. They may or may not be validated. Voiding a NCR can only be done with the con-currence of the Project Construction Quality Control Engineer. All NCR's are now statused on a periodic basi Allegation: Inspections were not performed on Fire Protection Systems as required by Bechtel WNP-2 Construction Quality Control Manual (CQCM) paragraph 3. Finding: The Allegation was not substantiated, although related i unresolved issues were identified.

The Bechtel Construction Quality Control Manual paragraph 3. states in part; "The requirements, procedures and instructions

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-4-for construction quality control contained in this manual shall be applied to Quality Class I, Quality Class II - Seismic I, Quality Class G - Seismic I, and other safety related items subject to the quality assurance provisions of 10 CFR 50, Appendix B (hereinafter referred to as Q-Items) and ASME Code,Section III items, Fire Protection Systems and Radwaste System The program applies during the construction-phase from time of receipt inspection and/or custody transfer until formal release for turnover to the Supply System. These requirements, proce-dures and instructions shall similarly be' applied to Q-Items and ASME Code,Section III items, Fire Protection Systems and Radwaste Systems which are formally returned by the Supply System to Bechtel for rework or repair."

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The inspector determined that definitive boundaries for inspection had not been established. Bechtel Quality Control Personnel contacted Bechtel Engineering for an interpretation regarding specific boundaries within the Fire Protection System that should be considered safety relate Eechtel engineering, after contacting the licensee and the A/E (Burns.

! and Roe) determined that the safety related boundary for fire protections systems was the wall of the building Once outside the building and underground the WPPSS fire protection

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engineer takes over the monitoring of construction activities.

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The technical support building is a WPPSS inspection responsi-bilit Bechtel concluded that the quality inspection program

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should be implemented in safety related areas only with regards

to the Fire Protection System. This determination conflicts with the Bechtel Construction Quality Control Manual. Pending clarification and resolution'of the directions described in the Bechtel Construction Quality Control Manual and those given.by Bechtel engineering this item is unresolved. (50-397/

82-12-01) Allegation: Some pipe hangers have not been areheated as required by Project Engineering Directive (PE))

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Findings: This allegation was not substantiate Nonconformance. reports (NCR's) have been written which document the process of thermal cutting of some pipe hangers without preheat. Those NCR's which were validated were dis-positioned as " Perform MT; if acceptable use Accept as i Those NCR's which were not validated were reviewed and

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determined to acceptable without further NDE.

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-5- Allegation: Inspections by Quality Control personnel were done using Information Drawings and non-controlled FSK drawings.

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Finding: The allegation was not substantiated due to previous

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licensee identification of issu Bechtel Construction Work Plan / Procedure GWP/P-8 states in part, "Information only drawings may be used for production purposes (Preparation of Quality Control Inspection Reports

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Systems, Weld Map Identification, Requisition Materials, etc.)

provided the user assures that the documents utilized agree with the " Controlled" stamped documents and/or DCL located at the Bechtel Control Stations."

Bechtel Quality Assurance conducted an audit of Bechtel Construction Quality Control to determine conformance to re-

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quirements.for preparing, processing, revising and controlling field inspection record One of deficiencies noted was that inspections were performed using unauthorized documents (FSK's)

for acceptance criteri Bechtel Proj ect Construction Quality i

Control Engineer subsequently issued instructions that all j installation inspections were to be performed using controlled i drawing Pending resolution of the audit finding concerning

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the previous use of un-controlled drawings this item is un-resolved (50-397/82-12-02) Allegation: Uncalibrated oxygen analyzer used during the welding proces Finding: The allegation was not substantiate There are no specific requirements for oxygen analyzer to be calibration on the job sit Vendors of oxygen analyzers recommend that any calibration required be done by the vendo The oxygen analyzers are adjusted prior to each

. use (field check) to read 21 percent oxygen, the normal oxygen content in air. No other adjustments or calibra-tions are require Allegation: Quality Control inspections performed prior to scoping for those inspections'.

Finding: The allegation was not substantiate Inspections on structural steel were conducted in part in accordance with Project Quality Control Instruction (QCI)

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No. 14631/W-1.00, Quality Control Instructions for Welding, Heat Treatment and Nondestructive Examinatio The-in-struction provided inspection activities for welding, heat treating and nondestructive testing of Quality Class 1 items and/or ASME III items. Bechtel has determined that Project Quality Control Instruction (QCI) No. 14631/C-2.10, Installation, Fabrication and Rework of Miscellaneous Metal and Structural Steel should be used on non ASME items. During the change over from one prccedure-to the other some inspections were started to Procedure W-1.00. They will be completed in accordance with Procedure C-2.10. Since the inspection packages contain forms from each procedure it appears that the inspections were not scoped prior to the conduct of the inspectio However form C-2.11 covers many welds of a structure such as a pipe slip restraints, therefore,'the form is not completed until the inspections are performed on the entire structur Instructions have been issued to the inspection personnel on the proper use of.each form and the methodology for completing the inspection packages'for ,

the components being inspected to QCI C-2,1 g. Allegation: When the reactor pressure-vessel:(RPV) was, set in place in 1977 it settled on a list from 1-7/I5! Inches

to a maximum of 2-1/16-inche Finding

The allegation was not substantiate The inspector reported in Report No. 50-387/82-07 that the.

.i greatest tilt of the RPV was 0.0048-inches at 45 . The licensee had previously performed a thorough investigation into the settling of the RPV. The investigation report

states in part, The RPV was set on the night of March 31, i 1977. Prior to the RPV being positioned, the bearing flage (or Base Plate), upon which it rests was measured for profile and elevation. Page two of General Electric Drawing M. !

I-A.l.6 illustrates that the bearing plate surface lies within

! a band of .046-inches above to .046-inches below its design elevation of 519-feet - 6 3/4-inches. Letter GEIBC-215-76-206, dated October 26, 1976, forwarded the RPV Base Plate data

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and described a design tilt for the bearing plate which shows it to be within .000 to .005-inches of design when considering

. the design til The RPV centerline was measured for perpendicularity on April 4, 1977, four days after the RPV was placed on the

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bearing plate. General Electric Drawing M.R.-I-A,4.5 shows that at the length of the RPV (about 80-feet), the RPV center-

line is only .2503-inches from true vertical. A quarter inch arc subtended at a distance of 80-feet is more than an order of magnitude less than the alleged RPV settling.

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At the inspectors request the present-position of the RPV flange was measured on May 26, 198 This survey showed the flange to be horizontal within about 5/32-inche These measurements were made on the forging surface rather than the machined surface of the flange, therefore, the variations of 5/32-inch is to be exp'ected, and the survey demonstrates that the vessel has not settled".

h. Allegation: Uncalibrated torque wrenches were used by Bechtel on quality class 1 systems and not recalibrated prior to being placed back in service The alleger stated that a bench check that he performed on April 7, 1982, determined that at least two torque wrenches previously used on Quality Class 1 systems were out of calibration. These wrenches and others of undertermined use were not returned to the calibration shop but were designated for " Class II use only" without a record check to determine effected Quality Class 1 wor A list of 23 wrenches effected was provide Finding: This allegation was not substantiate The inspector reviewed the qualification records of the 23 wrenches listed. These wrenches had been obtained by Bechtel from the 215 contractor (WBG). Initial calibration of these wrenches was performed at the WPPSS calibration facility at WNP-1 between November 1981 and March 198 These wrenches were not used for Bechtel work prior to this initial calibration. Each wrench was scheduled for recali-bration every six months starting with the date of initial Bechtel calibratio In early April 1982, a check of wrench calibration on a bench torque tester showed questionable results for the 23 wrenches detailed in the allegatio These wrenches were removed from service and sent to the WPPSS calibration lab at Unit 1 for recalibration. This process takes about 4 weeks to complete due to transportation and scheduling problem Between April 15 and April 22, 1982, 13 of of these wrenches were reported as "out-of-calibration" as received at the calibration la One wrench was still at the calibration lab on the date of this inspection (May 19, 1982) The remaining wrenches had been reported as "in-calibration" as received by the calibration lab after April 15, 198 .

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-8-The Bechtel equipment calibration supervisor had sent memos to the Bechtel Assistant Quality Control Manager on April 30, 1982,. stating that the 13 wrenches had been found out of calibration and requesting a record search to determine if these wrenches had been used on Quality Class 1 equipment. At the time of this inspection the Quality Control Organization was in the process of determin-i ing the Quality Class 1 work affe.cte NCR 763 was written on May 10, 1982, detailing the rework required due to the lack of calibration of 3 of~the 13 wrenches. Other NCR's were to be generated once the specific work affected was determined.

l The inspector found that the Bechtel actions had been 4 systematic and in accordance with procedures. The issue

! was being adequately controlled to assure proper resolutio . Allegation: Lockwashers were re-used on Concrete Expansion Anchors Under the 100 percent Retorque Program The alleger stated that lockwashers which had been installed by WBG under the nuts on concrete expansion anchors were reused by Bechtel even though. Burns and Roe Engineers re-quired replacement with new lockwashers when the nuts are loosened for the 100 percent retorque program.

4 Finding: This allegation was not substantiated.

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The inspector reviewed the requirements for lockwashers with Burns and Roe, the design engineer. Burns and Roe stated that no written directive'on the reuse of lock-washers had been issue Burns and Roe also stated that

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all expansion anchors were torqued to 150 percent of the design loa Burns and Roe stated that test performed on anchors with and without lockwashers at 120 percent i

preload showed no advantage due to the use of lockwasher Lockwashers were included in the design as a " good engineering practice". Burns and Roe engineers felt that it would be a good practice not to retorque a lock--

washer more than twice, but because of the test experience, did not deem it necessary to establish this as a design requiremen The Bechtel quality control manager stated ^that the~ reuse of lockwashers had been addressed several weeks prior to this inspection. Quality control inspection had requested guidance in the use of lockwashers for the 100. percent retorque of WBG hanger program. Bechtel engineering had

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-9 determined that the design specifications did not impose

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any special requirements in this area. As the anchors were not high strength bolts, reuse of the lockwashers would be acceptabl Bechtel procedure SWP/P-C-4 '.'100 percent Retroque Program" required that for Hilti expansion anchors without a lock-washer, an internal tooth lockwasher be installe Bechtel requirements appear to be within the design specifications and are technically acceptabl . Piping and Supports Matetial Control The inspector toured the material storage areas at the on-site fabrication shop and the general laydown area, interviewed quality control and construction supervision personnel, and examined records associated with specific material items. The inspectors' findings are noted: Piping support material stored near the fabrication shop contained painted heat numbers which did not in several cases correspond with the numbers stamped into the stee Specific examples are:

MATERIAL STAMPED PAINTED 9x25-4 channel #170W706 #170WO6 6x15-3 channel #B94851 #B9481 6x15-3 channel #B94851 #B94854 3.5x7-65 T-Section #123C90 #123C190 It appeared that the more easily identified painted number could result in errors on material control or associated documentation. The responsible GE personnel arranged for full examination / verification and remarking of the GE material. This was done under surveillance of a Bechtel quality control inspector as documented on inspection records 215-240-5-19-82 and 215-240-5-21-8 The GE receiving inspection reports RIR-35240, 35237 and 35238 (all dated September 24, 1979) showed that the stamped identification numbers were valid with regard to corresponding to acceptable material test report The GE/Bechtcl corrective action appeared to be adequat Piping and support materials within the fabrication shop area appeared to be clearly marked, however there were various materials marked and separated in a separate

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-10-holding are The shop inspection and craft personnel stated that this material had been released to the fab-rication shop from the general receiving laydown area, but that material identification discrepancies had sub-sequently been detected at the fabrication shop. The quality control inspector demonstrated cognizance of this matter through copies of material control records (#10346,10372 and 10384) . These showed that the dis-crepancies had been identified at the shop and the receiving-laydown personnel notifie Some of the items clearly involved transposition differences between the log books and the material markings:

HT - 2M1415 versus HT - ZM1415 (erroneous letter Z)

HT - 5570555 versus HT - 5570555 - 6 (suffix superfluous)

HT - 29694 (shown 1-inch Sch 80; actual 3/4-inch Sch 160)

To date, most of the specfic items have been resolved by returning the material to the laydown yar Discrepancies which could not be resolved by the receiving-laydown personnel would be addressed through the nonconformance report syste The fabrication shop personnel stated that they have had about 20 instances where the received material included discrepancies involving the heat number log book As a result, the shop had instituted an interim quality control receiving inspections and hold-area for incoming material from the receiving /laydown yar The Bechtel responsible quality control supervisor was cognizant of the interim action, which appears to be functioning adequatel c. Pipe support materials in the receiving and laydown area were clearly marked, stored in posted areas, and segregated by type and ASME class. Materials in a hold status, (where so labelled) were clearly segregated from acceptable materia A 5/8-inch steel plate was in a hold-area, due to questions raised by the fabrication shop personnel, in connection with heat number 3251 appearing on the material control record 10372. The plate was marked with a heat number (3251) and purchase order number (38274) which do not include 5/8-inch plate within their scop The material receiving report (MRR-2115 dated February 10, 1982) shows only 1/2-inch plate as having been received under the purchase orde .

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-11-Although this matter is under review within the Bechtel quality assurance function, it is identified here as a follow-up item for NRC revie (50-397/82-12-03)

4. Primary Containment

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The inspector was asked by the NRR Project Manager to ascertain if an out of round condition existed on the primary containmen The inspector transmitted to the project manager a document titled

"As-Build Drawing and Survey Index" for contract 213, Containment Vessel. This document will be reviewed by NRR to ascertain if

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condition of the containment vesse . Management Meeting The inspector met with licensee management as identified in paragraph 1, on May 27, 1982, to discuss the inspection findings

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, as detailed in this repor .

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