IR 05000460/1982008

IE Insp Rept 50-460/82-08 on 820426-30.Noncompliance Noted: Safety Platform 4625A & safety-related Beam 2749E Had Corrective Work Performed Prior to Generation of Nonconformance Repts

ML20054G691
Person / Time
Site:	Washington Public Power Supply System
Issue date:	05/27/1982
From:	Dangelo A, Dodds R, Narbut P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20054G684	List: IR 05000460/1982008 ML20054G683 ML20054G687
References
50-460-82-08, 50-460-82-8, NUDOCS 8206220211
Download: ML20054G691 (15)

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U. S. NUCLEAR RECUL\ TORY COMMISSION E.':. REGICN V

, *:~'3 Report No. S0-460/R2 OR Docket No. 50_460 License N CPPR-134 Safeguards Group

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Licensee: Wachinntnn Public Pnwpr Sunnly System P. O. Box 968 Richland. Washington 99352 Facility Name: Washington Nuclear Pro _iect No. 1 (WNP-1) -

Inspection at: WNP-1/4 Site. Benton County. Washington Inspection conducted: Anril 26-30. 1982 Inspectors: N 6/27[BZ P. P. Narbut, Reactor Inspector Date Signed

%w lYN4 A.D'Ang@d,ReactdFInspector Sb 7fg Datd Signed

= Date Si ned Approved by: ,

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R. T. Dodds, Chief, Reactor Project Section 2 ' Date/ S igned Reactor Construction' Projects Branch Summary:

Inspection during the period of April 26-30, 1982 Areas Inspected: Routine unannounced inspection by two regional based inspectors of licensee activities including licensee action on previous inspection findings, 10 CFR 50.55(e) reports and an examination of the decay heat removal heat exchangers. The inspection involved 62 inspector hours on site and 16 inspector hours in office by two NRC inspector Results: One item of noncompliance was identified concerning the structural steel contractor performing work prior to receiving written authorization for the work (paragraph 5.a).

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DETAILS

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, Persons Contacted Washington Public Power Supply System-

• R. W. Root, Acting Program Director i *C, R. Edwards, Project QA Manager j N. S. Porter, System Engineering Manager;

• M. E. Rodin, Senior QA Engineer

• M. J. Farrell, QA Specialist

• G. K. Dykeman, Design Engineering Manager

• A. D. Edmondson, Power Engineering Supervisoor

• R. Rockwood, Construction Coordinator

• L. C. Oakes, Senior Mechanical Engineer -

• C. B. Organ, Assistant Program Director Engineering

C. King, Welding Engineer R. Latore, Project Engineer-

, Bechtel Power Corporation (Bechtel)

• T. Fallon, Project CQCE

• J. L. Ruud, OA Engineer

'*J. B. Gatewocd, Project QA Engineer

• C. K. Kasch, yA Engineer T. Psomas, Lead QC Engineer, Maintenance

J. Kotter, Lead Contract Coordinator.

i United Engineers and Constructors,(UE&C)

• A. Edmondson, Power Engineering Supervisor S. Nathan, Supervising Engineer, Pipe-Analysis M. K. Ullah, Supervising Engineer, HVAC Bonneville Power Administration (BPA)

• D. O. Blacketer, Site Representative f Shurtleff and Andrews In ,

W. Lalor, Quality Assurance Manager

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-2- Babcock and Wilcox (B&W)

W. Willman, Project Manager

• Attended the exit interview of April'30, 1982 which was also attended by Mr. A. Toth, USNRC Senior Resident Inspector for WNP 1/ . Significant Events On April 29, 1982 the Supply System Executive Board and the Board of Directors announced the delay of construction on WNP-1 for up to five year . Site Tour The inspectors conducted a tour of containment activities upon arrival at the site. During the tour, the inspectors observed a flanged nozzle on the upper head of the east steam generator which was open to containment atmosphere and not sealed per the NSSS contractor's specification requirements. Supply System personnel were notified. At the exit interview, the Bechtel QC coordinator stated the condition had been correcte . Overview of Open Items During the inspection conducted April 5-9, 1982, IE Inspection Report 50-460/82-07, Bechtel QC personnel questioned whether some action could be taken regarding open NRC inspection items. It was stated that, of approximately 60 open items, about 30 were ready to clos During this inspection the licensee representatives presented 31 items which had been determined to be ready to close. The inspectors examined 13 of the items, and found 5 items were closeable and 7 items were not closeable due to insufficient information or actions not yet take One item was changed from an unresolved item to an item of noncompliance and given a new numbe At the exit interview the inspector discussed the apparent need for the licensee to look harder at the readiness of an item for closure and to assure that sufficient information was available to make that decisio .

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-3 Licensee Action on Previously Identified Items (Closed) (460/81-12-05) Unresolved Item: Work was performed prior to the issue of an authorizing documen (0pened Enforcement Item 50-460/81-08/01)

The original item was a partially substantiated allegation that

. work discrepancies were being reworked / repaired prior to processing contractor nonconformance reports (CNCR's) by using " quick fix" memorandum which were not prescribed by procedure. During the original inspection one case was described where corrective work was performed on beam 2749E prior to writing the nonconformance report and requesting corrective action. The licensee was given six example CNCRs and comitted to determine whether work was performed prior to the writing of the CNCR During this inspection, the item was determined to be.a'n item of noncompliance since the original beam, 2749E, was determined not to be an isolated case. Of the six CNCR's investigated by the licensee, two improperly had work performed before authorization, two properly had work performed after authorization and two were indeterminate since craft time sheets did not indicate when the work was performe In addition to the work done on beam 2749E described in report'

50-460/81-12 the other' item which had work performed before authorization was platform 4625A. Beam 4707C would not fit up to platform 4625A; specifically, the bolt holes would not properly alig The bolt hole in the lug of platform 4625A was plug welded and redrilled in a new locatio Af ter the work was done the final bolted assembly was inspected and verified by QC on September 24, 1982 on the Shurtleff and Andrews inspection form entitled "Qu ality Assurance Field Inspection Report for High Strength Bolts." The particular form of interest was filled out to indicate " Unit 1, Elevation 458'-4", Area E East Steam Gen E-314 C.O.F.L." and the entry of interest shows

"4625A to 4707C".

Nonconformance report 1-CNCR-207-461 was written on October 7, 1981 descrioing the fitup problem and recommending the corrective action which had already in fact ber, accomplished. The recommended action was approved by the engineer on October 19, 198 Contract specification 9779-207 Revision 47 paragraph 12.5.3.l states in part "Upon noting and documenting a nonconformance...

the Contractor...shall... provide a detailed disposition. The original form shall be submitted to the UE&C Field QA for UE&C Engineering concurrence. Work may proveed at the contractor's own risk pending UE&C Engineering concurrence."

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The accomplishment of safety related work prior to proper ' authorization -

for that work in accordance with approved procedures is considered an apparent item of noncompliance (Enforcement Item 50-460/82-08/01).

LIn review of the licensee's information package for this item the~ inspector noted that the Bechtel; analysis of action to prevent -

recurrence stated that Shurtleff and'Andrews is presently performing all work per work packages and that since all work is performed per the package system, no work can be done in the ficld prinr- -

to written direction. The inspector found, however, through interdews that the work package system was only partially implemented ,

and that a procedure was being developed for the system but hadi not been finalized or issued for us i The licensee personnel stated they had understood, based on the Bechtel analysis, that the package system procedure was issued and implemente The apparent misinformation in the Bechtel information was discussed at the exit intervie (Closed) (460/81-06-09) Followup Item: The method of tagging '

material in the laydown area needs to be resolve The original inspection which opened this item occurred during a transitional period when Bechtel was taking over the responsibility for the laydown area from UE&C. The UE&C system for controlling material had every item tagged as acceptable or unacceptabl The Bechtel system had unacceptable items tagged and segregated and acceptable items were not tagged. At the time of the previous inspection both systems were in us '

The licensee had committed to-determine how the laydown area would be handled and to reflect the decision in a procedure and in practic During this inspection the inspector examined the following applicable procedures:

. Bechtel WNP-1/4 Construction Quality Control Manual Rev. 1

. Bechtel procedure WNP-3, Equipment Receipt, Handling Storage and Housekeeping Rev. 4

. Bechtel Quality Control Instruction, QCI No. A-1.00 Status Tagging Rev. 1

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The procedures taken as a whole state that Bechtel will segregate and tag unacceptable items and will not tag acceptable ' item except that " Accept tags" will be' applied upon release of material '

from the laydown area when required by the contractor's quality:

assurance progra The inspector examined the laydown area and noted that the area contained items which were " accept" tagged, " reject" tagged and -

had no tags. Not all " reject" items were segregated. There had been an improvement in the method of. tagging in that all tags were firmly affixed and no detatched tags were observe The inspector interviewed laydown area personnel ?nd determined that material which is released from the area is visually checked for reject tags prior to release and each item is checked via the computer for any outstanding nonconformances. Therefore the system appears to ensure no unacceptable items are released for us The Bechtel laydown area personnel stated they had not been requested by contractors to apply accept tags, except in one case dealing with pipe whip restraints. The inspector interviewed the Foley Wismer Becker (FWB) QA Manager and determined that their program required accept tags but this was accomplished by FWB receipt inspection personnel upon receipt of material from the laydown are It appears the contractor's quality assurance program requirements for " accept" tagging are being me Based on the manner in which laydown area material is checked for nonconformances during release, this item is considered close (0 pen) (460/81-10-04) Followup Item: Foley Wismer Becker supplier i evaluation appears weak.

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The licensee initially submitted this item as closeable. After some initial examination by the inspector the licensee requested that the item not be examined further at that time. The reason for the withdrawal was that the licensee representatives believed that the revised FWB procedure, QCP-29, had been issued but it had not.

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-6- (0 pen) (460/81-10-05) Followup Item: Foley Wismer Becker supplier-audits appear wea The licensee also initially submitted this item as closeable and withdrew it from consideration after some initial examinatio The Bechtel status report had been closed based on expected completion dates however the actions had not been accomplished at the time of inspectio (Closed) (460/81-06-05) Followup Item: Incomplete weld filler metal documentatio This item was closed during this inspection based on the inspector's examination of weld filler metal control conducted and reported in IE Inspection Report 50-460/82-0 Additionally the inspector examined the Bechtel surveillance records for weld filler metal control for contracts 207, 253, 257, 211, 246, 216, 243 and 204. These surveillances had been ordered by the Program Director as a result of this ite f. (0 pen) (460/81-06-01) Followup Item: Piping cleanliness practices require followu The licensee had presented this item as closeable however examination of the material in the licensee's information package did not appear to deal directly with the item. The item dealt with the cleanliness of piping and the observed use of piping for temporary storage of items such as solvent cans and welding helmet The information in the licensee's package dealt with increased surveillances for general housekeeping. The inspector interviewed the supervisor of the Bechtel forces which would do such surveillance The supervisors stated the surveillances were intended to be general housekeeping surveillances and were not geared to piping internals. Bechtel personnel responsible for the followup item stated they had not yet closed the item or submitted it to the Supply System. Therefore this item remains ope .

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, (Closed) (460/79-14-01) Followup Item: . Temporary supports for pipin The original item dealt with J. A. Jones temporary supports for piping. The inspector had noted piping supported by other piping with the possibility of deformation having occurred. The licensee had committed to evaluate the adequacy of controls on temporary pipe supports and to evaluate the specific observed piping for deformatio During this inspection the inspector examined J. A. Jones procedure WI-016.1 Revision 2D dated April 16, 1982. The procedure had been changed to prohibit attaching temporary supports to installed plant equipment such pumps, tanks, installed piping and permanent support The inspector examined surveillance reports Nos. 571 of December 12, 1979 and 616 of January 17, 1980 which were written to record the cold springing in the pipe. The surveillance reports were closed on January 21, 1980 after the piping in question had additional supports installe This item is closed based on the actions taken and the fact that temporary supports will be inspected in the normal course of future inspection At the exit interview the inspector discussed the licensee's information package on this item. The package lacked the surveillance report no. 571 which identified the cold springing issue. Also discussed was the time required to address and resolve this ite The item was identified in December 1979 and the procedure change was issued in April 198 (0 pen) (460/81-02-03) Followup Item: University Nuclear System Incorporated (UNSI) has a misconception as to when a nonconformance report should be generate The licensee representatives submitted this item as closeable on the basis that a specification revision had been issued to UNSI. The licensee no longer considered the item closeable when it was determined that the UNSI implementing procedure had not been revised.

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6. Licensee Action on 50.55(e) Construction Deficiency Reports

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-8- (0 pen) 50.55(e) Construction Deficiency Report of' December 28, 1981 - Thermal Expansion of Containment Steel Licensee representatives submitted this item for closure'on the basis that their final-letter had been submitted-which stated the actions required would be tracked as_a Part'21 report through UE& ,

The inspector declined to close the item on the basis that-site -

modification actions would have to be accomplished prior-to closin this ite (Closed) 50.55(e) Construction Deficiency Report of January 26, 1982 - Square Tubing by DuBois Steel has extensive linear indication The licensee's final report on this item was letter G01-82-63 of February 26, 198 The letter states the deficient condition was isolated to a single heat and that installed material from the defective heat has been removed. The. total quantity of defective steel was accounted for and placed on hol This item is considered closed based on the licensee's response, (Unit 1/ Closed - Unit 4/Open) 50.55(e) Construction Deficiency" Report of October 2, 1981 - Defective DeLaval valve springs for:

diesel generato The licensee's final report on this ite'm is letter G01-1;81.374 of November 11, 1981. The letter states that the diesel generator spare parts cylinder head assemblies were inspected for defective valve springs and that the spare parts were tagged and placed on hold. The letter also states the valve springs installed in the head assemblies with the diesel generator units would be checked during the test and startup procedure, that the procedure would include an inspection point for valve springs. The letter further states that since the procedure had not been written at that time the inspection requirement would be entered into the Project Action Tracking Syste The inspector examined the surveillance report 1-ETAL-06 dated November 6, 1981 which recorded the spare parts inspection and taggin .

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-9-The inspector interviewed responsible personnel and determined that the inspection point requirement for the startup procedure inspection of valve springs in the diesel generator units had not been entered in the Projects Action Tr a cking Syste During the inspection week, licensee personnel generated Startup Deficiency Report, SDR-M99 dated April 29, 1982 for Unit 1 which-requires inspection of the valve springs for the Unit 1 diesel generators during startup. The deficiency report will ensure the valve springs are inspected during startup testing of Unit This item is considered closed for Unit 1 but will remain open for Unit At the exit interview, the inspector discussed the fact that, although the licensee considered the item ready to be closed, the inspection point requirement for the startup procedure had not been entered-in a tracking system even though_the licensee stated this would be done in their final letter to the NRC on this ite d. (0 pen) Potential 50.55(e) Construction Deficiency Report of March 1, 1982 - Cable trays attached to the containment with concrete expansion anchor bolt The licensee determined this item was not reportable and so stated in a telephone call, M. Rodin (WPPSS) to P. Narbut (NRC) on March 22, 198 The licensee position was based on UE&C letter UEWP-82-5246 of March 19, 1982 which stated the conduit supports anchored to the containment shell have relatively low loads and high safety factors. The letter also states the practice of installing Hilti-Kwik Bolts in the containment shell had been discontinued as poor engineering pra:tice. UE&C letter UEBEC-82-5141 of. February 22, 1982 requested that all contractors immediately stop performing work which requires drilling into or removal of any concrete'

within the ASME III Division 2 Code boundary since performance of such work by non-authorized personnel could jeopardize "N" stamping the WNP-1 containmen The inspector declined to close the item on the basis that the issue of the "N" stamp certification for previously' completed work by non-authorized personnel had not been resolve .

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e. (0 pen) Potential 50.55(e) Construction Deficiency Report of November 10, 1981 - Pipe Rupture Restraints purchased to-Quality Class 2 versus Quality Class 1 requirements The licensee reported a Construction Deficiency Report (CDR)

on November 11, 1981 regarding pipe rupture restraints (PRR)

purchased to Quality Class 2 requirements in lieu of Quality Class 1 requirements. The Supply System has evaluated the problem and determined the subject PRR's not reportable under 10 CFR 50.55(e) and so informed the NRC by telephone on December 4, 198 Pipe rupture restraints are generally structural steel frames designed and fabricated to control pipe movement following a pipe rupture such that the pipe would not impact or produce a jet force that would impair the function of nuclear safety related components or cause another rupture of a nuclear safety related piping system. PRR's do not prevent a postulated pipe rupture from occurring, but PRR's do perform a safety function in mitigating the consequence of a postulated accident by preventing the pipe whip from inducing additional failures in other nuclear safety related structures or component The WNP-1 PSAR details the quality assurance program and defines the quality classifications as follows: Any structure, systen or design characteristic that prevents or mitigates the consequences of a postulated accident is classified as Quality Class Any non-safety related item including the radioactive waste system is classified as Quality Class II/II Augmented or Quality Class G/G Augmente The WNP-1 PSAR does not specifically identify the quality class of PRR's, however, within chapter 3.6, the PSAR does state that protection against pipe whip effects is provided within as well as outside containment. PRR's were supplied to WNP-1 under two purchase contracts, numbers 9779-134 and 9779-151. The subject PRR's were supplied under contract number 9779-151 and the licensee's documentation indicates that the Quality Class II Augmented program was applied to the contractor, Corner and Lada, Cranston, Rhode Island. Contract 9779-151 supplied all PRR's used at WNP-1 except for the Reactor Coolant System (RCS) PRR's which were supplied under contract number 9779-134, 80 ECON. The Architect-Engineer (AE) considers the PRR's not to be nuclear safety related as was documented in UE&C letter numbered UEWP-82-5066 dated January 22, 1982 which states:

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"The'PRR's by definition, are not' intended to prevent postulated accidents. They do perform a passive function in mitigating the consequences of a postulated accident such as ruptured pipe forming a plastic hinge and whipping against other " essential structures, systems and components" impairing their ability.to-perform safety related functions. It must be understood, however, that the primary accident is the pipe rupture and the associated loss of capability of the affected system to perform its intended

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function. The prevention of such rupture is outside the capability I of the PRR's, and the mitigation of its consequence also lies with the necessary action ~or inaction of other redundant /back-up systems. The PRR is only performing a secondary safety function of assuring that the primary accident does not develop into a secondary or multiple accident From the above rationale the PRR's are considered not safety related components and Quality Class I designation was not applie Rather, Quality Class II-Augmented with the following supplemental

controls was applie . Q.A. Audit to verify vendor quality program acceptability and adherence theret . 100% final inspection and release by UE&C Resident Vendor Surveillance Representativ . Code travelers were used to control and document shop fabrication processes which were reviewed and approved by the-fabricator's Q.A. manager. These travelers are maintained in their file and are available upon request."

The inspector determined that the site quality data packages for PRR's do not contain all the above stated documentation within the data package At present, the current quality classification of the PRR's supplied by contract number 9779-151 is not in compliance with the PSA At the exit interview, the licensee stated that the Supply System and United Engineers and Constructors are presently reviewing the issue of whether the PRR's are or are not nuclear safety related. The inspector's understanding of a safety related item as described in 10 CFR 50 and the licensee's PSAR definition of Quality Class 1 indicates that the PRR's should have been manufactured to Quality Class 1 requirements, otherwise a PSAR deviation should be initiated. The item will remain open and be reviewed during a future inspectio ;

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7. Additional Inspection Items Structural Steel Splice Plates .

During the inspection the inspector was made aware of a problem with structural steel splice plates which had excessive gap between the structural members and the splice plates. The contractor's representatives stated that nonconformance reports had been written for 47 unsatisfactory splice plates discovered in a sample of 91 splice plates. A nonconformance had been written but not dispositioned at the time of inspection on other inaccessible splice plates which are covered in structural concret This item will be inspected further during a future inspectio (Followup Item 50-460/82-08/02) HMA Relays The NRC had received a " Service Advice" frem General Electric Power System Management Business Department dated November 12, 1981 dealing with uninsulated flexible leads on HMA relay The licensee had been requested to ascertain whether HMA relays were used in safety related service. During this inspection the licensee provided WPPSS interoffice m emorandum E14-GKD-82-041 dated March 5, 1982 which stated an investigation had been conducted and that no GE type HMA relays had been used on Projects-1/ This item is considered closed and is assigned a number for record purposes onl (Followup Item 50-460/82-08/03) Niagra Kinetics cement for HVAC flexible connections During a previous inspection the inspector was made aware of possible problems with a cement manufactured by Niagra Kinetics and used by Buffalo Forge Company for flexible connections to the Air-Handling Unit During this inspection the inspector determined that per a UE&C memorandum dated April 16, 1982 the cement is a barium sulfate loaded vinyl and that the service conditions described in that memorandum are mil The inspector reviewed the locations of the. Air Handling Units with the cognizant engineer and verified the locations were mild environmentally. The inspector also reviewed drawings of the axial fans used in containment and verified the cement was not used on those fan assemblie The remaining issues on the Niagra cement are:

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-13-(1) Closecut of Corrective Action Request CAR No. 22-4 dated April 12,-1982 which identifies that no certified test report was submitted for the cement (organic material) as is required j

by Purchase Specification 9779-22 Section 15A paragraph

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30 (2) Provision of the rationale by which Buffalo Forge and UE&C used Niagra Kinetics as a qualified supplier of Quality Class I cement whereas University Nuclear Systems'and UE&C were unable to find Niagra Kinetics a qualified supplier of Quality Class 1 cement and purchased the cement as Quality Class 2 cemen This item will be inspect- 1 further in a future inspectio (Followup Item 50-460/82-08/04).

8. Safety Related Components The decay heat removal heat exchangers (tag numbers DHR-HX-1A and 28) were examined for correct weld size as specified on the heat exchanger fabrication drawing and the quality assurance data package for the heat exchangers was examined for documentation as required by ASME cod The onsite inspection of the DHR heat exchangers was prompted by an inspection of Ametek, Inc. by the Vendor Inspection Branch of NRC which identified several software problems and possibly hardware problems with decay heat removal heat exchangers manufactured for other nuclear facilitie Review of Quality Records During a review of the QA data package for DHR-HX-1A and 28, the fabrication drawing, showing the minimum weld sizes as specified by the heat exchanger designer, was not contained in the QA data package or available elsewhere onsite for inspection. The heat exchanger shop welds could not be verified by the inspector for the drawing minimum size. The onsite NSSS vendor project manager did obtain, by telephone, the specified weld sizes from B&W's home office and the inspector verified equipment welds did meet this minimum size. The licensee has committed to obtain the drawings needed to verify the weld size of shop welding performed on the DHR heat exchangers. The weld sizes examined by the inspector were:

Telephoned Location Minimum Allowable Fillet Size, i Stainless steel fillet weld of doubler 1/2 plate to head Carbon steel fillet weld connecting 5/8 flange to inlet nozzle on the secondary size of the heat exchanger Carbon steel fillet weld connecting 5/8 bolting flange to shell assembly

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-14-During a review of the " Certificate of Test" for electrode chemistry and deposited weld metal mechanical properties, the inspector identified two certificates of test for the same wire lot, flux lot and weld number. Although both certificates were within ASME specification SFA-5.17 allowables the difference between the measured results was large.

The specific tests in question were both found in the QA data package for DHR-HX-1A weld numbers 2F, 4F, 6F and 7F. Both tests were performed on the same electrode wire lot, number DD320 and flux lot, number IJ Electrode wire and flux were certified to ASME classification F71-EL12. The first certificate of test was performed by the Lincoln Electric Company dated January 24, 1977, order number 26329, Supply System file number 13N-4815-2, the second certificate of test was performed by Dirats Testing dated February 17, 1977, Test number 20921, Supply System file number 13N-4815- Both certificates of test list test results for elongation, as required by ASME NB-2430, which are within allowable. However, the two tests show results which are different by 12%. The diffarence between test results for elongation of the test specimen appear to be large when compared to the difference between yield strength and tensile strength which are 1% and 7%, respectivel The certificate of test also contains chemical analysis of deposited weld metal (not an ASME code requirement) for the above welds in question. The difference in test results between the two certificates of test is quite high with Manganese, Silicon and Phosphorus being 30%, 31% and 26% higher, respectively on the tests performed by Dirats Testin The differences in chemical and physical properties would suggest that the analyses were not performed on the same sample materia The licensee has committed to identify which certificate of test is the official certified test as. required by ASME code and to verify that the correct welding procedure was used to produce the deposited weld meta The subject of additional data needed for DHR heat exchangers (drawings showing weld size and correct certificate of test)

will be examined during a future inspection (Followup Item 50-460/82-08/05). Exit Interview The persons identified in paragraph 1 met with the inspectors on April 30, 1982. The scope of the inspection and the findings were discussed as stated in the repor _ . . . _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - - _

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