IR 05000397/1983027
| ML20024F688 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/16/1983 |
| From: | Dodds R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20024F682 | List: |
| References | |
| 50-397-83-27, NUDOCS 8309090579 | |
| Download: ML20024F688 (11) | |
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S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-397/83-27 Docket No. 50-397 License No. CPPR-93 Licensee: Washington Public Supply System
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P. O. Box 968
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Richland, Washington-99352 Facility Name: Washington Nuclear Projects No. 2 (WNP-2)
Inspection.at: VMP-2 Site, Benton County, Washington Inspection conducted: June 1-30, 1983
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Inspectors:
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A'. D. Toth, Seniod Resident Inspector Dite $igned Approved by:
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R. T. Dodds, Chief D6te $igned Reactor Projects Section 1 Summary:
Inspection on June 1-30, 1983 (Report No. 50-397/83-27)
I Areas Inspected: Routine, unannounced inspection of construction quality
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reverification activities, allegations and employee concerns, and status of l'
previous inspection findings. The inspector also' assisted with the NRC Construction Assessment Team inspections of concrete, piping and supports.
The inspe,ction involved ^116 inspector hours on-site by the construction
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resident. inspector.
Findings: No items' of noncompliance or deviations were identified.
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PDR ADOCK 05000397 i
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DETAILS
1.
Persons Contacted Washington Public Power Supply System (WPPSS)
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Carlisle, Program Director G. Afflerback, Assistant Operations Manager
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Boarder, Quality Assurance Engineer
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Crisp, Construction Manager L. Floyd, Quality Assurance Engineer
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Garvin, Quality Engineering Manager R. Glasscock, Licensing and Assurance Director
- P. Harness, Engineer J. Honekamp, Assistant to the Managing Director
- R. Johnson, Project Quality Assurance Manager
- R. Knawa, Reverification Program Manager J. Martin, Operations Manager M. Monopoli, Manager of Operations Assurance Programs P. Powell, Licensing Engineer R. Ramsgate, Reverification Program Engineer D. Walker, Operations Quality Assurance Manager Burns and Roe Engineering Incorporated (BRI)
G. Englert, Pipe Support Engineer J. Mahoney, Group Leader - Pipe Supports J. Mayovsky, Engineer R. Sanan, Resident Group Supervisor - Civil H. Tuthill, Engineering Quality Assurance Manager
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Donthier, Senior Quality Assurance Engineer Becthel Power Corporation J. Bellomy, Reverification Group Inspector
- W. Boarder, Quality Assurance Engineer i
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Cosgrove, Quality Assurance Engineer
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B. Davis, Reverification Group Engineer R. Duchon, Engineer Specialist, Civil, San Francisco
- J. Gatewood, Project Quality Assurance Engineer
- D. Johnson, Manager of Quality
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Leach, Reverification Group Supervisor T. Logan, Scheduling Manager
'T. Mangelsdcrf, Project Manager C. Ruud, Quality Assurance Engineer L. Tuthill, Concrete Consultant Bonneville Power Administration P. Grady, Site Representative
'* Denotes personnel present at the exit management meeting.
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In. addition to the personel noted above, the inspector interviewed various other ".onstruction, engineering, and quality control personnel from~the licensee and contractor organizations.
2.
. General The resident inspector was on-site June 1 ~, 8-11, 13-17, and 20-24, 1983. During June 8-22, 1983, the resident inspector assisted the NRC Construction Appraisal Team in its activities.
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Several regional office inspectors visited the site during the month for routine inspection activities. Their activities are documented in other separate inspections reports. These and other NRC associated personnel site visits are described below.
Regional inspectors and management (D. Schuster, R. Fish, and L. Ivey)
were onsite June 1-2, 1983, to observe and evaluate the licensee performance of the emergency response excercise.
The Regional Administrator (J. Martin) was on-site Jm 1, 1983 to l
observe the emergency response excercise.
A radiation safety inspector (G. Yuhas) was on-site June 1-9, 1983.
Two NRC licensing staff members (R. Froelich and R. Eckenrode) were onsite June 6-9, 1983, along with consultants from the Lawrence Livermore National Laboratory (J. Savage, K. Harman, and W. Rousseau) to review control room human factors.
A group of thirteen inspectors (R. Heishman, W. Albert, W. Hansen, K. Herring, E. Merschoof, R. Rohrbacher, and H. Wong) and five consultants (R. Compton, D. Ford, W. Marini, E. Martindale, and F. Piemental) were on-site June 6-22, 1983, as part of an NRC Construction Appraisal Team, in the becond phase of its special inspection. A representative of the NRC Human Factors Branch (F.
Forscher) attended as an observer June 9-10, 1983. A member of the Human Factors Branch (M. Malloy) also visited the site June 20.
Two NRC staff members (P. Farron and V. Hodge) were on-site June 14-16 to discuss NRC events analysis functions, the ENS communications system, and to tour the facility.
A regional office inspection supervisor (L. Norderhaug) and an inspector (C. Schwan) were on-site June 20-22, 1983 regarding the pending security system inspection in July 1983.
Regional office management (J. Martin, J. Crews, D. Sternberg, and R. Dodds) were on-site June 21-22, 1983 to discuss aspects of the construction verification program and to attend the exit meeting of the NRC Construction Appraisal Team on June 22, 1983.
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A regional office inspection supervisor (R. Dodds) was onsite June 23, 1983 to review status of the resident inspection activities.
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Two NRC examiners (L. Wiens and R. Pate) and consultants from Pacific Northwest Laboratories (PNL) (I. Levy and C. Henager) and from EG&E (W. Cliff and G. Sly) were on-site June 7-9 and 13-15 to conduct examinations for operator licensing of plant staff. A regional office inspector was onsite June 21-23, 1983, to review licensee actions regarding matters reported under 10 CFR 50.55(e).
NRC headquarters inspection staff (M. Gaitanis and J. Levine), and consultants from PNL (D. Schultz and E. King) were onsite Junc 23 through July 1, 1983, to examine the emergency response program procedures and training. Regional coordinating inspectors were onsite June 20-23 (R. Fish) and June 23-July 1, 1983, (H. North).
3.
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 reverification program which includes review of records and reinspe:tions of hardware installed prior to July 1980.
An NRC inspection team visited the site in February 1983 to assess implementation of the July 17, 1980 Supply System commitments (NRC Inspection Report 50-397/83-10).
Results of the visit were discussed in meetings of March 9 and 17, and the Supply System submitted a summary clarification of the commitment status by letter dated April 18, 1983.
At a Region V office meeting on June 7, 1983 (NRC Inspection Report 50-397/83-25), the principal issues were clarified and NRC management identified the areas that warranted additional attention. The Supply System management offered key commitments which were later amplified at a June 21, 1983 meeting with NRC on-site.
At this meeting the Supply
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System addressed the eight NRC concerns described in NRC Inspection Report 50-397/83-25.
The. commitments to NRC in response to the June 17, 1980 inquiry have been adjusted by the Supply System over the duration of the committed construction verification program effetts. The NRC Region V office was generally informed of the adjustments via bi-monthly reports submitted by the Supply System. The adjustments have been summari7ed, at Region V request, in the Supply System April' 18, 1983 letter to NRC. Those adjustments, as a response =to the eight NRC concerns summarized below, are acceptable to the NRC Region V office:
a.
Sampling of hardware appeared warranted for contractors which furnished prepurchased material and equipment and contractors
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defined by the Supply System as " inactive."
The Supply System has now established a program for some field checking of hardware and detailed inspection of hardware as initial field checks documentation review results may suggest.
b.
Ddfinition is required for the logic for sampling selection and distribution for active contracts, including time periods when work was accompliche _-_
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The Supply System committed to documentation of such definitions into the' final reports. For current information, the Supply System
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stated that a 10 percent sampling basis was selected as significant, although prior remedial programs or analysis of reverification
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. findings have in several cases expanded the sample to 100 percent.
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The candidate areas for sample selection excluded items which had already been subject to rework or other reinspection efforts, or which had not been completed and final inspected prior to July 1980.
The Supply System also showed that pipe supports, as one example, had covered a spectrum of work accomplishment dates and had encompassed various safety related process systems, c.
Some clarification is required of the basis for judging the acceptablility of contractor's past work based on reverification program results.
The Supply System committed to documentation of such basis in the final report. For current information, the Supply System provided a table titled " Quality Verification Matrix," which identified each critical work activity, the associated estimated percentage of work done prior to June 1980, the contractors which performed the work, and key verification elements, (including identification of the various review, reinspection, and test activities which have been considered to establish the acceptability of installed work).
d.
Definition is required for the methodology used for evaluating the results of review and reinspection in determining need for expansion of sample size.
The Supply System committed to documentation of such information in the final report. For current information, the Supply System provided a summary of the deficiency evaluation process, including sorting for common causes and characteristics, consideration of safety significance, and extrapolation to populations not reinspected.
e.
Sampling of contractor's NDE activities appeared warranted as an evaluation of such activities.
The Supply System has now established a program to assess the NDE activities of the various contractors. This includes the use of a logic diagram describing the evaluation procers for active site contracts, including reviews and decision points for repeat NDE.
The Supply System identified significant effarts for the mechanical contractor work, incleding an extensive radiograph review, preservice inspections, and pipe whip restraint and sacrificial shield wall corrective action programs. For prepurchased equipment, recognition will be given to their ASME status; reviews of radiographs may be conducted if related documentation suggests a problem.
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Review.of procedures for technical adequacy appears warranted for prepurchased equipment and inactive contracts.
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The 9upply. System has now established a program to perform such
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_ technical reviews for contractors that furnished critical or unique
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coniponents and components that have not been subjected to other 7 ~
adequate reinspection programs.
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NRC' review of the planned content of the final QVP Summary Report appears desirable
This. planned content was discussed with, and provided to NRC
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Region V management on June 21, 1983.
Included were a summary
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h.
-Consideration of the NRC Construction Assessment Team findings
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appears warranted in evaluating the conclusions reached by the
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reverification program.
The Supply System committed to consider the relationship of such findings for work performed prior to July 1980. A logic diagram was
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presented to facilitate considerations where the reverification
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program reinspected items similar to those inspected by the NRC team.
(The logic does not recognize that the NRC team may have
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inspected areas not add essed by the reverification program, e.g.,
concrete excavation.)-
4.
Licensee Actions Regarding NRC Inspection Findings The inspector examined records and interviewed personnel regarding licensee actions on matters reported in previous NRC inspection reports:
a.
(Open) Follow-up Item (397/79-16-05) - Piping Weld Profiles The original item, and associated follow-up (documented in NRC Inspection Reports 50-397/80-01 and 80-04), described three issues.
'The inspector examined the Bechtel quality assurance organization files of corrective actions'taken'and verification reviews conducted. These demonstrated that the issues had been addressed
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and corrective actions taken:
(1) Weld transition configurations at joints of items of unequal diameter'did not appear to meet ASME Code requirements for 3:1 slope and appeared to contain consequent stress risers. Five examples of this item were identified.
Of the five examples, WBG repaired the three associated with valves RHR-V-3A, 14B, and 68A. Field weld 1 of MS-547-2 was included as an exception on an April 15, 1982 Certificate of Code Status that was provided to Bechtel as part of work turnover activities; final disposition will be the responsibility of Bechtel.. Field weld 3 of MS-547-3 was.
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determined by WBG to not be nonconforming.
Subsequenty, Bechtel has obtained an August 12, 1982 Washington-State concurrence to apply the Summer 1976 Addenda to ASME Code
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Section III provisions NB4520, NC4250, and ND4250. These allow a 1.732:1 taper cercared to the 3:1 taper required by the otherwise applicable ASME Winter 1973 Addenda.
Bechtel has identified this matter as Generic Problea Area 3, referenced in Procedure RVP-3.00, for consideration by reverification program inspectors during their sampling inspections of piping system. These inspections have been completed and the Bechtel quality assurance department has determined that the reverification inspectics: to date have not identified departures from the revised acceptance criteria as a generic problem.
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lhe licensee actionr were incomplete relative to the following:
(a) Determination that MS-547-3 field weld 3 been reinspected under the new criteria; (NRC Inspection Report 50-397/80-01 noted that its condition appeared to be the same as the rejected MS-547-2 field weld 1).
(b) Determination that MS-547-2 field weld I been repaired by Bechtel.
e (2) Large bore piping welds, prepared for inservice inspection ultransonic examinations contained evidence of grinding deeper
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than the base material surface, with possible compromise of the minimum required pipe wall thickness.
As documented in NRC Inspection Report 50-397/80-01, the NRC inspector accepted the licensee's actions which involved checking ther acutal pipe wall thickness with ultrasonic measurement and determining compliance with the minimum thickness required by design. The areas in question were found to be acceptable.
The more general question of overgrinding, and other aspects of minimum pipe wall thickness encroachment, have been addressed in NRC Inspection Report 50-397/80-08 (item 80-08-21), and subsequent licensee reports to NRC under 10 CFR 50.55(e).
It has been the subject of extensive reinspection and rework activities.
Progress on this aspect will be reported in the future under item 80-08-21.
(3) Small bore piping ends, prepared for socket welding, contained evidence of grinding deeper than the base material surface, with possible compromise of the minimum required pipe wall thickness.
This was reported to NRC under 10 CFR 50.55(e) via Report 80 dated November 25, 1981. An engineering directive, PED-215-3336, required ultrasonic measurements of pipe wall thickness at socket welds, including all ASME Class A welds, and'20 each of ASME Class B and Class C socket welds of various systems and pressure ratings. The engineer documented receipt
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of and evaluation of the measurements of 187 weld ends, via letter BRBEC-81-2416. The data for the 187 weld ends showed nine that were below specified thickn(ss by no more than
.006-inch and were acceptable in comparison to Code required thickness and safety factors.
The licensee actions were incomplete regarding the following:
(a) Evaluation of the five vendor welds for Code acceptability.
(b) Determination that a generic veedar problem does not exist and/or incorporation of this into the reverification program for prepurchased equipment.
At the exit meeting, the Bechtel representative stated that these matters had been addressed and documentation of the resolution was being compiled for NRC review.
This item remains unresolved pending completion of the licensee actions noted above.
b.
(Closed) Noncompliance Item (397/82-27-04) - Inadequate inspection instructions for evaluation of welds of pipe support strut end-brackets to piping curved surfaces.
The Supply System corrective actions for this matter are documented in letters to NRC dated February 2 and May 5,1983. The Supply System's Quality Assurance Surveillance Report 83-243-SS reports verification that this matter has been corrected for both small bore and large bore piping supports. The corrective actions were completed on May 20, 1983, with issuance of the design guide M400 and calculations which justified acceptance of the welds in question. This completion date was later than the April 29, 1983 date committed to the NRC. This matter had been brought to the attention of the Supply System's quality assurance manager by the surveillance staff, who highlighted the lack of detailed communication between the Engineer sad Construction Manager regarding such commitment dates.
This matter is closed.
'(Closed) Followup Item (397/83-03-02) - Control of Drawing c.
Interim Revisions (DIR's).
An ex-employee of Burns and Roe contacted the Supply System quality assurance office January 6, 1983, to complain of her experiences in document control. Particular allegations were made regarding control of drawing interim revision (DIR) documents, drug abuse, and her qualifications for her work assignments while previously employed at the mechanical contractor (WBG) offices. The employee identified no specific incorrect design, fabrication, or hardware deficiencies. The individual also contacted the resident NRC inspector on January 19, 1983.
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The Supply System quality assurance and security representatives interviewed the individual on January 17, 1983, and grouped her complaints into a total of nine separate concerns. The Supply System follow-up site investigations substantiated two the the allegations, but considered these not significant with regard to impact'on. safety-related hardware. Corrective actions were
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accomplished and appeared to address the concerns adequately.
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.The Burns and Roe emp1'oyee's principal' complaints had to do with the
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,Bechtel handling of drawing interim revisions (DIRs), a' type
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document which'provided installation information to facilitate s
implementatin of design drawing requirements. During the same
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period as the individual's employment with the responsible Burns and j -
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Roe gr6up :(June' 24 through December 31, 1982),a Bechtel internal
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audit was condu'ted (November 11, 1983) which identified problems c
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'* January'6 and 20, 1983. This was recorded in audit finding QAF-3 of
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' Bechtel: audit 3-1-3, for which corrective action was mandatory and
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in; progress (but not completed until after January 1983). The
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Supply System's investigation after January 20, 1983 noted the
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~Bechtel audit activity.
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.The' Burns and Roe' employee also commented regarding alcohol / drug
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related matters on-site. 'This information was acted upon by the Supply System, which does not condone such matters, and which has
" ' routinely conducted. a low-profile security program that includes investigations'into drug / alcohol related matters. This security program was given increased visibility on January 10, 1983, with the establishment of a site wide drug / alcohol abuse hotline program.
.This included posting of notices in prominent locations on-site and
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issuance of information notices to employees through the plant mail
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system. The Supply _ System actions are agressive toward minimizing problems in this area.
'No items of noncompliance have been identified.
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i The ex-employee has approached various public media with her complaints, as well as NRC.
In view of that search for public
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' exposure, this report includes the following summary of the Supply System investigation, for public record purposes:
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~ Allegation Results
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BRI procedures for logging BRI Procedure WNP-2-059 does not require DIRs requires the originator entering individual's name in log.
be identified in the log Procedure does state that BPC when rather than the organization requesting a DIR number will give name name, which is presently and organization. This requirement
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probably caused confusion.
2.
Doccaents are being BRI procedure does not preclude the co~pleted and signed in use of pencil. For 55 DIRs sampled, no
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pencil rather than black pencil changes were identified.
ink as required by procedures.
3.
Willful disregard fcr site
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25 DIRs were tracked through the process
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~ to determine procedural compliance. The and being told by her flow and maintenance of DIRs is being Supervisor to deviate from adequately controlled; however, the approved procedures, method for assigning and validating DIR numbers is not being strictly adhered to.
2Apparently because of the high volume of DIRs required on Bechtel's backshift work, there is an informal agreement between BRI/BPC t'o allow BPC to accumulate a' day's backlog of DIRs on their log
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of assignment of the correct DIR number,
' and then BRI sends-the log back to BPC signify'ing agreement with assigned numbers or noting required changes. The current BRI DIR clerk has found only two instances since'10/82 requiring correction.
This particular activity is not described in Procedure WNP-2-059. This practice is not; creating'any safety problem.
Procedure WNP-2-059 has been revised to reflect current practices.
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Original DIRS have been 55 DIRs were sampled to determine if issued contrary to proced-any were missing; none were.
ural requirements that
originals be kept in files.
BRI procedure requires copies to be maintained,-not-originals.
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Within BPC files, original Original Bechtel procedures required DIRs are being stamped "For stamping "Information Only" on Information Only", rather controlled copies of DIRs.
than issuing a copy stamped Subsequent revisions deleted this
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requirement.
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Allegation Results 6.
DIRs are being received by See above
BRI from BPC without a Bechtel stamp contrary to PBC procedures.
7.
The BRI DIR log does_not A-saaple of 56 dif ferent isometrics agree with the Bechtel were. checked. -Each of these
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DIR log. The BPC log,.
total of 244 DIR log entries.
included from 4 to 5 DIRs for a for instance, wi11' indicate
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t a higher revision number Three discrepancies were noted, two
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for a DIR than the BRI.. log.
in the BPC log and one in the BRI log.
j BRI to sample on routine basis to
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assure logs are consistent.
8.
Performed work and inspection It was determined that, while activities while working for employed by WBG, the alleger worked WBG that were beyond/outside under others with certificates of of her job description.
conformance (C of C) and work packages.
9.
Documentation clerks are being BPC interviewed the alleger's super-allowed to do field walkdowns visors concerning duties while employed and inspections such as weld by WBG under their direction. Both
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verification and completion supervisors stated that at no time of C of Cs.
during her employment did she have any technical responsibilities such as field walkdowns, inspections, or (
certification of C of Cs.
d.
(Closed) Follow-up Item (897/83-03-03) - Ambiguous Sampling Basis for Reverification Program Activities t
f This specific. matter has been addressed in the context of NRC
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general. reviews of the reverification program conducted in February 1983 (NRC Inspection Report 50-397/83-10, paragraph 3.g),
on June 7, 1983 (NRC report 50-397/83-25 paragraph 2.c.(2) and 2.c.(4)), and on June 21, 1983 (discussed in paragraph 3 of this report).
Further NRC follow-up action will be in the context of the I
results of the June 7, 1983 meeting.
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As a separate issue, this matter is considered closed.
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(Closed) Follow-up Item (397/83-05-02) - Absence of Reverification Program Technical Reviews of Procedures for Prepurchased Material an Inactive Site Contractor Work This specific matter has been addressed 'in the context of NRC
, general reviews of the reverification program, conducted in February
'1983 (NRC Inspection Report 50-397/83-10, paragraph 3.b.), on June 7, 1983 (NRC Inspection ~ Report 50-397/83-25, paragraph 2.c.(6)), and on June 21,1983 (discussed in paragraph 3 of this report). Further NRC follow-up action will be in the context of the results of the June 7, 1983 meeting.
As a separate issue, this matter is considered closed.
f.
(Closed) Follow-up Item (397/83-10-01) - Licensee Submittal and NRC Review of Commitment Changes Relative to the June 17, 1980 NRC 10 CFR 50.54.(f) Information Request The NRC Inspection Report 50-397/83-10 (paragraph 3) identified eleven questions regarding the implementation of the original
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commitments. The Supply System replied to each item and provided commitments to perform additional efforts relative to four items (3.a through 3.d).
Item "3.a" involved a key effort of formally summarizing for NRC all chcnges to the original commitments. That summary was submitted to NRC by letter dated April 18, 1983.
the NRC Region V staff evaluated that submittal and the related replies to the eleven questions noted above. The NRC staff concerns were clarified and presented to the Supply System at a June 7, 1983 status meeting at the NRC Region V office (NRC Inspection Report 50-397/83-25). Further NRC follow-up action will be in the context of the results of that meeting.
This item is closed, s
5.
Management Meeting
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The inspector met with licensee representatives routinely to discuss the status of inspection findings, including various Construction Assessment Team progress meetings. On July 8, 1983, the inspector met with the WPPSS Program Director and other representatives of the Supply System and the prime contractors to summarize inspection findings.
Persons contacted who attended this meeting are so noted (*) in paragraph 1 of this report.
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