IR 05000397/1983010
| ML20023C497 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/15/1983 |
| From: | Dodds R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20023C489 | List: |
| References | |
| 50-397-83-10, NUDOCS 8305170381 | |
| Download: ML20023C497 (14) | |
Text
..
.
..
_-. - -.__ -.
-
.
_
_.
.
.
.
.
,
,.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
,
j Report No. 50-397/83-10 Docket No. 50-397 License No. CPPR-93
,
Licensee: Washington Public Power Supply System
P. O. Box 968 Richland, Washington 99352 i
Facility Name: Washington Nuclear Project No. 2 (WNP-2)
_
Inspection at: WNP-2 Site, Benton County, Washington i
Inspection conducted:. March 1 -31, 1983 (/n'!f)
Inspectors:
(
A. D. T6th, Senior' Resident Inspector DathS[gned MJ f7 Approved by:
f R.' I. Ifo~dds, Chief Date/ Signed
,
Reactor Projects Section 1 Summary:
i
.
Inspe_ction on March 1-31, 1983 (Report No. 50-397/83-10)
Areas' Inspected: Routine, unannounced inspection of pipe support records, i
construction quality reverification activities, and construction management j
topics.
!
l The inspection involved 75 inspector hours on-site by the construction resident inspector.
'
..
)
l
.
'.
t 8305 L70381 830418
'
PDR ADOCK 05000 O
,
'
r
,,-ve-m-,:
,,n,
-, -, -,.
n
.,n,,,
,m,,.~,,,,.,..,_,.,,
.---,.w.,.n,.n,,.,,,.,_,.,,,,
,,..,,.,.., - _ _,.,,.,, _,.,,, _ _ -.,..,,,,.
.
-
...
-_.
.
-...
_.-.
- -.
- -..
.
._...
i
.
h DETAILS
1.
Persons Contacted Washington Public Power Supply System (WPPSS)
G. Blackburn, Test and Startup Supervisor
,
J.'Demelo, Startup Engineer-(System 10.0)
- C. Dickenson,-Senior Construction Engineer
- J. Garvin, Quality Engineering Manager R. Glasscock, Licensing and Assurance Director J. Honekamp, Assistant to the Managing Director
- R. Johnson, Project Quality Assurance Manager J. Kassakatis, Test Group Supervisor R. Knawa, Reverification Program Manager if J. Latta, Test Engineer l
G. Martin,' Operations Manager
'R.MatlockjProgramDirector
>
J. Snyder, Test Engineer D.~ Timmins, Technical Assistant - Program Director
!
E. Wright, Operations Quality Assurance Engineer
' Burns and Roe Engineering Incorporated (BRI)
W. Murphy, Pipe Support Lead Engineer
&
- A. Luksic, Licensing Engineer
- ~
- W Gonthier, Site Quality Assurance Engineer
.
'
Bechtel Power Corporation J. Bellomy, Reverification Group Inspector
.
- D.
Cosgrove, Quality Assurance Engineer B. Davis, Reverification Group Engineer J. Gatewood, Project Quality Assurance Engineer
' a C. Headrick, Project Quality Control Engineer
,
D. Johnson, Manager of Quality
!
,
i
{
M. Leach, Reverification Group Supervisor C. Ruud, Quality Assurance Engineer j-
- Denotes personnel present at the exit management meeting.
'
.
' -
In addition to the personnel noted above, the inspector interviewed various other construction, engineering, and quality control personnel i
'
from the licensee and construction management organizations.
i
- 2.
General The resident inspector was on-site March 3-4, 7-12, 14-18, 21-22,
-and 28-31.
This included general inspection of work in progress on Saturday, March 12, 1983.
1
,----e
--e--
- +
wt7e+=-es wv
~ew-
-r e t e --- m r e--
~r e-e--+-
-wy+
,
--w-n--+
c --wwe Ne e *--e na- *-=--ev+
ww-*
t-*--wvww=-+
m'v-*-mm-+-w-,ew-me v-
+ w wme"--nrm-e-+
-
h m
-
,
.
.-q'
1 t..
-
The resident inspector reviewed procedures for preoperational testing of
_
,
the high pressure core spray system, and witnessed portions of preoperational testing of the uninterruptible instrument power system and
'
the standby. liquid control system. These activities are documented in the operations related NRC resident inspection report (50-397/83-12) for
'
.
-
~
'
' the month of March.
A regional office operations inspector (D. Willett) was on-site j
'
,
March 7-11, 1983. A regional office construction inspector (J. Elin) was
'
on-site March 28-31 and April 1, 1983.
A regional office supervisor (R. Dodds) was on-site March 7-10, 1983, to review the status of the construction and pre-operational inspection program, and to discuss the construction reverification program with licensee site management.
Regional management personnel (J. Crews, D. Sternberg, T. Bishop, and R. Dodds) met with project management March 17, 1983 to discuss the status of licensee actions in response to the NRC June 17, 1980 request under 10 CFR 50.54(f).
3.
Construction Reverification Program In response to the June 17, 1980 NRC inquiry under 10 CFR 50.54(f), the Supply System, Bechtel, and site contractors have been engaged in a construction reverification program which includes review of records and reinspections of hardware installed prior to July 1980.
Reports of the reverification program' activities have been submitted to NRC by the licensee on a bi-monthly basis since 1980.
In February 1983, a regional office team of management personnel had surveyed the overall status of this program; this included records reviews and interviews of personnel during a February 15-18, 1983 visit to the site. The results of that survey were described to the licensee during a March 9, 1983 visit by a regional supervisor. The Supply System provided additional information and commitments during the March 17, 1983 visit of the regional management staff. The licensee was informed that
^
the NRC would be considering these items in the overall follow-up of the-quality verification program.
l Some of the survey results involved equipment purchased by Burns and Roe, early in the life of the project. This was an area currently under review by the resident inspector, who then focused his efforts on the specific questions raised by the survey team relative to equipment contract 24.
Results of these efforts were documented in the report for l
the February 1-28, 1983 period (Report 50-397/83-05). Specific results of the survey, and licensee commitments are summarized below. The Supply System stated that some revised actions were planned for four of the
' items in question (a. through d. below):
.
Changes to Supply System commitments in the 50.54(f) response have a.
been made by the Supply System, but NRC specific concurrence with these changes has not been obtained through the Region V office.
,
t
>
,
,--.~,c
-
..r-
-
--,.r.3.,,.y
,-,yw-,w--
-%,_..e c y
..,%
c,ew
-
-.--,m_.
. -y..--
,,. -
,w-r-----
e v - + i----
-e
-
m------t-'
-
.
The Supply System committed to actions to more clearly define and provide justification for program changes.
b.
The Supply System did not assess SAR compliance and technical adequacy of procedures, during review of inactive site contracts and purchased-equipment contracts.
The Supply System stated that the 62 contracts in question will be reviewed to identify unique or complex components (as proposed in the original response to the 50.54(f) inquiry), and hardware inspections-possibly performed to ascertain SAR compliance and technical adequacy. The NRC management stated that the procedure review matter may requir'e additional consideration.
c.
The Supply System has arrived at conclusions regarding records accuracy, for closed contracts and purchased equipment contracts, without commensurate hardware reinspection or rigorous comparison with other data.
The Supply System stated that the 62 contracts in question will be reviewed to identify unique or complex components and hardware inspection possibly performed to ascertain SAR compliance and adequacy.
d.
The Supply System personnel appear to have not performed their.
reviews in compliance with established procedures, for inactive contracts and purchased equipment contracts (e.g., contract 24).
The Supply System noted that this matter has been specifically addressed by the resident inspector in February 1983, and that the matter is being investigated and will be addressed with NRC.
e.
The Supply System has. arrived at conclusions regarding the adequacy of some contractor's work, although some document reviews have not yet been completed (which might impact on such conclusions).
,
The Supply System stated that the reviews in question had reached l
stages of completion where sufficient data was available to arrive at the conclusions in question.
'
f.
The Supply System reverification of prior work did not appear to have made full use of findings resulting from the procedure reviews conducted during the work restart effort for each contractor.
Although a generic problem list was developed, it did not include, or overly generalized, some issues identified by the restart reviewers, e.g.:
(1) The Civil contractor (210A) procedures reflected deficiencies in concrete placement criteria, such as cover, temperature, free fall, layer depth, curing times and methods, and reinforcing steel placement.
t (2)
Intergranular corrosion test data for weld procedure 809-6 had I
not addressed location of weld. metal, base metal and heat
!
l
'
_ __ _
_
. _ _ _
_
_-
_
_
_ _ _. _
-,
__ _
_
. _ - _
.
.
affected zones, and two of the locations were unsatisfactory.
This was listed in the generic problem list as " Miscellaneous problems with weld documentation and inspection."
The Supply System replied with examples of where restart review results were used during the reverification program. The Supply System apparently considered the extent of this effort sufficient.
'
g.
The Supply System did not clearly define the criteria for recommending sample size and type of reinspection of hardware.
The Supply System stated that it had committed to reinspect a significant sample of the plant and that 10 percent sample was arbitrarily selected to be both representative and significant.
Where major portions of the plant were identified to have inadequate documentation or hardware, specialized investigative, and corrective programs were instigated.
h.
The Supply System did not appear to fully monitor the self-verification activities of contractors.
The Supply System described some understaffing problems and some compensating audit and surveillance activities, which they considered adequate.
i.
The Supply System has arrived at conclusions regarding the adequacy of some contractors' personnel qualifications without benefit of a review of qualifications procedures, qualifications records, or examples of hardware.
The Supply System stated that this commitment was not fully met, may not be needed, and would be addressed in further communications with NRC.
j.
The Supply System has not placed emphasis on receiving inspection reviews, regarding unique equipment or first time nuclear suppliers, as a focal point for hardware reinspection analysis.
l The Supply System stated that this commitment was not fully met, may
'
not be needed, and would be addressed in further communications with NRC.
(
k.
The Supply System appears to have applied reinspection criteria j
which is less than SAR commitments, in some cases.
l The Supply System stated that the only deviation from all applicable
,
l codes and standards expressed in the FSAR is the revised visual examination criteria of procedure QVI-09. This has now been
,
l submitted to NRC for review as an FSAR change.
l The Supply System stated that it had always been the intent to modify the commitments of the 50.54(f) response as circumstances warranted to perform meaningful reviews. Although deviations from
!
l l
'
_
-
-. -- -
- -. _ _ -., _ - - _ _ _ _ _.. _. -
.___, - - - _.. -.,
-. _. _
. _ _ -,,
,
- commitments were identified during the NRC survey activity, these generally appeared to have been at least implied in prior bi-monthly reports to NRC. The lack of highlighting and identification for NRC concurrence has resulted in the current team perceptions of commitment deviations and a commitment for the Supply System to compile the changes in a clear manner for NRC review and action.
The submittal of the commitment changes and the NRC's response will be followed up (50-397/83-10-01).
4.
Construction Reverification Program - Inactive Contract Reinspections The inspector examined the plans and sample selection basis for reinspection of structural steel work previously completed under inactive contract 206. The reinspection was performed by the Bechtel reverification (RVG) inspectors.
The responsible RVG inspector stated that he had researched the closed contract 206 files to deteraine the scope of work performed. He had identified applicable structural steel drawings from installation packages maintained at the WPPSS vault. From these drawings were identified all the structural steel beams which were installed prior to default of the contract (subsequent work was assumed by contract 215, and subject to separate active-contract category reverification activities).
For some of this work, the quality assurance organization had identified that required documentation was unavailable (and now unretrievable from the contractor who went into default several years ago). The Supply System has condemned the adequacy of that work pending specific resolution definition and execution of corrective actions; this has been excluded from the RVG reinspection sample selection. This appeared to be an acceptable approach.
The candidate work was limited to welding aspects, since bolting work is currently being addressed under a nonconformance report (No. 10203) which will require specific evaluation and corrective actions regarding prior work. This appeared to be an acceptable approach.
The candidate welding work included 123 beams in the reactor building, 17 beam seats within the suppression pool, and 46 beams within the suppression pool. Except for the beam seats and a dozen beam / column transition sections, the steel in the suppression pool used bolted connections. The reinspection sample was taken from only the reactor building group, since the suppression pool had been painted and filled with water, such that accessibility to beams was now difficult. This appeared to be a minor exception to the Supply System baseline policy that construction work not proceed to make prior work inaccessible for reinspection.
Bechtel attempted to compensate for the omission, through selection of a total sample size based upon 10 percent of the total candidate work (selected from the welds of steel in the reactor building). This
-
appeared to encompass a representative sample of fillet and full penetration welds. A table of random numbers was used to select beams for reinspection. Additionally, Bechtel personnel performed visual
-
--
._
_
_
.
- - - -
- -
-.
_
-
.
examination of two significant full penetration welds on each of the beam / column transition sections within the wetwell, to ascertain presence and adequate fill of each weld. The inspector accompanied the Bechtel
. personnel, noting no discrepancies. This examination provided additional confidence in the representativeness of the sampling pian discussed above. A set of annotated drawings attested to the samples selected, and clearly showed a randomness which encompassed several drawings and various structural steel beam sizes. The sample selection was documented on the standard sampling plan format provided by an approved procedure (RVI-02).
No items of noncompliance were identified.
5.
Construction Reverification Program - System Reports For active site contracts, Bechtel had delegated the reinspection of prior work to the contractors, with B(chtel overview. However, for the me'chanical contractor, Bechtel had assumed responsibilities for system completion, and has been performing reinspection with Bechtel staff.
This activity was performed on a system-by-system basis, for 37 safety-related systems. A separate interim report has been issued for each such system, which will then be integrated into one final report, following overall program completion.
The interim reports have been made available to the resident inspector as they have been issued. The inspector examined the following such reports this period:
7.1 High Pressure Core Spray - Hardware reinspection was conducted for:
1 of 12 small bore piping isometric drawings 1 of 13 large bore piping isometric drawings 2 of 44 large bore piping support details 8.0 Low Pressure Core Spray - Hardware reinspection was conducted for:
2 of 21 small bore piping isometric drawings 2 of 12 large bore piping isometric drawings 5 of 44 large bore piping support details 10.0 Standby Liquid Control System - Hardware reinspection was conducted for:
2 of 19 small bore piping isometric drawings 1 of 3 large bore piping isometric drawings There were no large bore piping support details.
25.0 Primary Containment Atmospheric Monitoring - Hardware reinspection was conducted for:
One of ten penetration stubs located at the drywell bulkhead.
47.1 Standby Diesel Generator - Hardware reinspection was conducted
'
.
f for:
9 of 92 small bore piping isometric drawings 2 of 12 large bore piping isometric drawings 2 of 56 large bore piping support details 55.0 Diesel Oil Storage & Transfer - Hardware reinspection was conducted for:
l'of 8 small bore piping isometric drawings 1 of 6 large bore piping isometric drawings There were no large bore piping support details.
48.2 Digital Electro-Hydraulic Control - Hardware reinspection was conducted for:
1 of 4 small bore piping isometric drawings 1 of 1 large bore piping isometric drawings 2 of 2 large bore piping support details.
55.0 Tower Makeup System (QCII/ SCI)
1 of 6 large bore piping hanger details.
The sample size was then increased to 100%, due to weld deficiencies.
The piping support sample size for some of the critical systems (e.g.,
HPCS, LPCS, SDG) did not appear to meet the 10 percent criteria previously described to NRC. The Supply System representative stated
"that the supports samples were derived from the piping isometrics which were generally randomly selected and, in some cases, a selected piping isometric did not happen to have many supports. The representative stated that the 10 percent criteria would be met, at least for the overall population of piping supports, if not on a system-by-system basis.
Inspection findings described in the interim reports included minor piping support raterial, weld size, and configuration matters which have already been identified by the WBG status as-build drawing program, or which would likely be identified by the final as-built drawing program currently in progress for Quality Class I piping and supports.
No items of noncompliance or deviations were identified at this time.
6.
As-Built Drawing Program This matter has been discussed in prior NRC inspection reports, especially 50-397/83-05. The " Status As-Built" drawings (by WBG) have not all been reviewed by the architect engineer for resolution with stress analysis calculations. For Quality Class II/ Seismic Category I pipe supports, this will represent the final stress resolution. For Quality Class I piping and supports, a final as-built verification will also be made (by Bechtel), and the drawings each compared against the
" Status As-Built" drawing and differences addressed in stress calculations as necessary.
y-w"
-m
--
-
e 5m-pm mvvmg
---
- " - - +
"
--r--
'
__
.
Following Bechtel internal audit findings and NRC inspector review, Bechtel instituted improved training and controls to assure accuracy of their final as-built drawings. For work done prior to such improvements, a program was instituted to evaluate the work of each engineer. During the current month, the inspector verified that such evaluations had been done And corrective actions taken where necessary.
In some cases Bechtel found it prudent to again reexamine some or all of the work of specific individuals, based upon the results of the audits. There were 30 engineers who have been classified as being not qualified, relative to the work they performed prior to the program improvements. These have been identified to all system completion team leaders so that their work could be withdrawn from the as-built cycle for rework. Records showed that such drawings have been identified by the team leaders, in addition to the as-built supervisor (who reviews each as-built drawing before final release to the engineer). The training, checking, and audit provisions appear to assure a very high level of confidence in the-accuracy of the as-built drawings for this plant.
No items of noncompliance were identified.
7.
Construction Reverification Program - Licensee Actions On Previous
.
s Inspection Findings (Closed) Noncompliance (50-397/82-27-01) - Apparent improper engineering disposition of reverification inspection finding.
This matter was discussed in NRC inspection reports 50-397/83-03 (paragraph 3) and 50-397/83-05 (paragraph 5.f) and licensee action appeared appropriate. As additional follow-up of this matter, the Supply System Technical Assistant to the Program Director conducted a special audit of reverification program quality control inspection records (QCIRs) which had included any " Accept-As-Is" disposition by the design engineer. Of approximately 300 QCIRs written using the in-field disposition mechanism of procedure QVI-08, approximately 87 involved such
" Accept-As-Is" dispositions; 27 of these were examined by the Technical Assistant. His conclusions agreed with the assessment which has been made by the engineer's supervision, i.e.,
the dispositions all involved minor matters well within the delegated authority of the engineer. Where appropriate, check calculations and/or reference to the original calculation files were included. For QCIRs reviewed by the inspector, a similar conclusion resulted.
The inspector selected the group of 57 QCIRs associated with the large bore piping isometric drawings. Of these, 27 included identification of some discrepancy, and 8 involved accept-as-is disposition in the field by the Burns and Roe design engineer.
Particular QCIRs reviewed included the following:
MS-529-12, 538-4, 539-4.5, 542-1.2, 552-5.6, and 553-2 SW-250-31.30, 251-19.22, 90-1.3, 295-39.42, 296-33.36 SGT-622 EDR-526 FDR-527-7.9
- --
-
- - -
, - _. _. -. -
, _ - -. -. - - -
--,.
-
__
,
k
'
.
,
.
CAC-627-5.9
'
CSP-808-1.3 RHR-883-30.33, 897-15.19, 898-33, and 898-36.38 LPCS-756-22.24
-
HPCS-632-1.3 RCIC-659-18.21, 660-2.4, 660-5 FRW-418-7.8, 438-1.2 RRC-569-1.2 SLC-045-13.15 The dispositon actions all appeared to be sound and reasonable. No items of noncompliance nor deviaions were identified.
This matter is closed.
8.
Quality Assurance Documentation Review Criteria The Supply System quality assurance department routinely reviews a sample of the documentation submitted by Bechtel for retention as permanent plant records. Review results have included identification of both minor administrative errors and more significant technical errors. Previously, the detection of administrative errors in the sample apparently led to rejection of the entire group of documentation, with requirement for Bechtel re-review of the entire group. Bechtel has proposed a guideline which facilitates acceptance of a group of documentation, without re-review, if only a few administrative type discrepancies are identified. A March 9, 1983, document BECWNP2-83-0307 identifies a basis for sampling and definitions of administrative versus technical errors (technical errors ordinarily require that the hardware be reinspected).
On March 17, 1983 the Bechtel and Supply System quality assurance and quality control managers met with the resident inspector to discuss this guideline prior to its implementation. The Supply System quality control manager described his proposed performance standards for maximum number of administrative errors in any sample (15 percent). He stated that the quality assurance review procedures would be revised to reflect the guidelines of the proposal. The guidelines appeared to be conducive to l
addressing substance rather than form.
No items of noncompliance were identified.
t l
9.
Pipe Supports and Hangers Records l
The inspector examined records of Bechtel shop fabrication and field
'
installation of piping mechanical shock suppressor assemblies (snubbers)
for the following pipe supports:
i a.
RFW -171 Model PSA-10 Fabrication and Installation
!
b.
RCC-482 Model PSA-1 Fabrication and Installation l
c.
MSRV-2C-5 Model PSA-10 Fabrication and Installation
_
.
-.
.
__
.
__
l
-
,
d.
MSRV-3C-4 Model PSA-10 Fabrication and Installation e.
MSRV-4C-4 Model PSA-10 Fabrication
'
f.
RHR-SB-33 Model PSA-10 Fabrication g.
RCC-337 Model PSA-3 Fabrication He also observed the shop fabrication activities in progress on snubbers
'MS-SC-3 (Model PSA-35) and RFW-23 (Model PSA-3) and interviewed the assigned quality control inspector and the shop engineer. He also examined inspection records and interviewed Bechtel quality control supervisors who were adininistering reinspections of sway strut and
',
snubber end bracket bearings.
The inspector examined the work package and installation drawing (hanger detail) for each of these supports, and the associated quality control inspection records. He examined the Welder's Performance Qualification List (dated March 3, 1983) and related qualifications maintenance records. He examined the WPPSS quality assurance surveillance report 83-227-BCM, dated January 20, 1983, which encompassed snubbers for supports RHR-479 and MS-SC-3.
These documents an/ work in progress were considered relative to applicable fabrication and installation criteria of the following Burns and Roe and Bechtel control documents:
.
a.
Contract 215 specification sections 15R and 17A b.
Specification change PED-215-H-H197 c.
Installation Procedure SWP/P-P-1 (revision 6)
d.
Procedure Change Notices SWP/P-P-1-13, 14 and 15 Construction Tolerance Drawing H501 Sheets 1-3, (April 9, 1982)
e.
f.
Quality Control Instruction P-2.10 (Revisions 3 and 6)
The records demonstrated quality control inspections of the following aspects:
type and classification of the support, proper location and spacing, compliance with applicable procedures, weld identification, proper weld material, and welder qualification. Support MSRV-2C-5 involved welding a support plate directly to piping; the applicable weld procedures and materials were referenced, and the special inspection record format for pipe welding (W-1.00) had been completed. The quality control inspection records which documented these activities included log numbers 2847, 2747, 3148, 2548, 2758, 2134, 2722, 753, 2758, 299, 4247, 2829, and 4517.
No items of noncompliance were identified.
_ _,. _
...
_ _ _ _ _.. _ __
_
_ _
_ _ _
__
___
_ _ _ _ _ _ _ _
.,
-_ _ _ _ _ _ _ _ _ _ _ _ _
.
,
!
,
10.
Licensee Actions On Employee Concerns Bechtel had initiated a program around January 1983 to effect "Special Exit Interview" of'each quality control or non-manual employee who left
-
the project (due to reductions in force or other terminations reasons).
The interview included a written form to be signed by the employee, which provided the opportunity, and extended the invitation for the individual to identify any quality concerns that he may have. The questions included:
a.
Do you know or are you aware of any unresolved problems with the quality of workmanship for safety-related items on this project? If yes, explain, b.
Do you know or are you aware of any unresolved specification or code violations that are or have been committed at this project.
If yes, explain.
c.
Did you attempt to bring these possible violations to the attention of your supervisors? What were the results?
This effort, coupled with the established " Hotline" program, provides additional routes for licensee management to assure identification of all significant quality concerns. The Bechtel quality assurance organization has assumed the responsibility for investigation of identified matters, and has adopted these as a unique, additional quality management tool.
With the increasing redt.ctions in force associated with the completion of the construction, there have been increasing positive responses to the inte rviews. The records have been made available to the resident inspector. The inspector examined nine statements obtained March 9 and 11, 1983. These show that the program has been successful in solidifying generalized comments into specifics. A March 15, 1983 memorandum charges the Bechtel Project Quality Assurance Engineer with investigation and obtaining corrective actions.
No major hardware discrepancies were identified.
No items of noncompliance were identified.
11.
Employee Concerns and Allegations
The inspector had examined data relating to concerns expressed by site l
employees during routine inspection interviews. The following item was examined in conjunction with and subsequent to items discussed in NRC inspection reports 50-397/82-29 and 83-03, and is summarized here for record purposes. This item is one of several which arose during a union dispute, where the quality control inspectors had approached the NRC inspector to question the competence of the supervision and the degree of their support in attacking quality problems. As with the other items, this item reflected some complexities of documenting engineering and work control decisions, but contained no elements of substance to demonstrate inadequate construction, specifically:
.
.
-
.
A quality control inspector had made reference to nonconformance report NCR-471, for pipe support RHR-SA-58, suggesting that the engineering _
' disposition may not have been correct. The disposition had made reference to an engineering directive (PED-W-B875), which appeared to not have been issued until. welding on the pipe support had been completed.
The employee also believed that the welders were not formally qualified for the full penetration weld work which they had performed. He stated that twice (October 27, 1982 and November 2, 1982) he tried to issue a new NCR to document the improper dispositon, but these were not
" validated" by his supervisor.
,
The inspector interviewed the responsible quality control supervision and examined: quality control inspection instructions in effect at the time of the work (QCI-14631/W-1.00 dated January 26, 1982); quality control inspection records (RHR<2>-874-1.3-15 and 16); related engineering directives (PED-215-H-4363, H-875, H-B949 and W-C252); related nonconformance reports (NCR-471 and 9519); related request for information (RFI-C0500-792); and qualification records for welders BP-173
-
and BP-175 (for procedures P1-A-LH and PI-A-LH-Structural).
The records showed that the welders were qualified (February 17 and 18, 1982) for full penetration welding (February 19 and 20, 1982) with applicable welding procedures.
Interviews and records showed that appropriate engineering direction had been in effect since November 18, 1980, although it had been subject to several modifications as attempts were made to clarify weld symbols. The PED B875 had been in effect for a short period of time, but was superceded by PED-C252 due to an administrative consideration. The quality control inspection records for final inspection of the pipe support (RHR-SA-58) reference the NCR-471 and related applicable documents noted above, and appears to be technically adequate. The action by the supervisor appears to have been acceptable. To improve handling of such matters, Bechtel has instituted a system of pre-numbered NCRs and procedures to allow voiding of NCRs with documentation of rationale. Such voiding action requires the concurrence of the Project Quality Control Engineer, as noted in NRC inspection report 50-397/83-03.
l No items of noncompliance were identified.
!
12.
Missing Valve Bonnet Nut During a March 12, 1983 off-shift inspection, the inspector identified l
that one of 24 nuts was missing from the bonnet studs of 18-inch valve l
RHR-V-21 of the residual heat removal system C-loop.
The system was under
pressure, with a loop flushing operation in progress. The Supply System l
test and startup supervision could identify no authorized work raquest l
nor other record of approval for removal of the missing nut.
They could not identify the persons responsible for its absence.
The WPPSS records supervisor stated that the manufacturer's records
,
(Contract 41B) attest to proper torque of bolting prior to shipment to
!
WPPSS. This is shown in Assembly Inspection Report, dated May 22, 1975.
l l
l l
l 1'
'
- -
,
,
..
--- _ - -
-.
--
--
-
-
.
The Bechtel field engineer and quality control personnel stated that their records show no authorized work on the valve which would not have involved disassembly of the valve. The related Bechtel Isometric Revision Request and Notice of Construction Completion (IRR) for drawing
'
RHR-897-6.9 (dated February 2, 1983) shows construction complete with no exceptions.
The WPPSS test engineer stated that he had no knowledge of the missing nut, and that the condition apparently occurred since his November 1982 walkdown inspection of the system.
The removal of the bonnet nut appears to have been uncontrolled, and performed without knowledge of responsible technical and management personnel. This was discussed in a management meeting with Operations on April 4, 1983. The licensee stated that the rest of the nuts were satisfactorily torque tested. This has been classified as an isolated incident, but of the type that bears watching.
Of equal or greater concern to the licensee is where tagged circuit breakers have been changed to the energized position. Operations is in the process of establishing zone control for personnel as construction winds down in hopes of limiting these types of problems.
13.
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. An unresolved item disclosed during this inspection is discussed in paragraph 3 of this report.
14.
Management Meeting The inspector met with the WPPSS Project Quality Assurance Manager approximately weekly to discuss the status of inspection findings and other inspector activities relating to this project. On April 1, 1983 the inspector met with the Project Quality Assurance Manager and other representatives of the Program Director to summarize inspection findings.
Persons contacted who attended this meeting are so noted (*) in paragraph 1 of this report.
l
.
,