IR 05000508/1978009
| ML19259B626 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 01/15/1979 |
| From: | Bishop T, Haynes R, Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19259B618 | List: |
| References | |
| 50-508-78-09, 50-508-78-9, 50-509-78-09, 50-509-78-9, NUDOCS 7903130462 | |
| Download: ML19259B626 (12) | |
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U.S. fiUCLEAR REGULATORY C0'GISSION OFFICE OF ITISPECTION Af!D ENFORCEMEilT
REGION V
50-508/78-09
' Report flo. 50-509/78-09 50-508 CPPR-154 Docket f!o. 50-509 License No. CPPR-155 Safeguards Group Licensee: Washington Public Power Supply System P. O. Box 468 Richland, Washington 99352 Facility Name: WNP-3 and WNP-5 Inspection at:
WNP-3 and WNP-5 Site (Satsop)
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Inspection Ccnducted: December 6-21, 1978 Inspectors: b "kfM)0 f.,2 7 9 D. F. IGesch. Reactor Inspector Date Signed T. W. Bishop, ReaMor Inspector
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'Date Signed 1-12 '19 T. W. Hutson, Reactor Inspector Date Signed Other Accompanying
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R. C. Haynp Chief, Project bec' ion Date Signed Approved By:
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R. C. HaynesNef, Project Sectf n, Reactor Date Signed Construction and Engineering Support Branch
Inspection during period of December 6-21, 1978 (Report Ins. 50-508/78-09 and 50-509/78-09 Areas Inspected: Special, unannounced inspection by regional based inspectors and one supervisor of licensee actions to correct Pittsburgh Testing Laboratory documentation and personnel certification discrepancies; Immediate Action Letter compliance actions; structural concrete procedure review, work observation and record review;and 0A audits and surveillances. The inspection involved 116 hours0.00134 days <br />0.0322 hours <br />1.917989e-4 weeks <br />4.4138e-5 months <br /> by four NRC inspectors.
390313 09b IE:V Form 219(2)
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Sut. mary (Con't.):
(Reportflos. 50-508/78-09 and 50-509/78-09)
Results: Of the four areas inspected, no items of noncompliance or deviations were identified in three areas, one item of noncompliance (failure to submit contractor data sheets to AE) and one unresolved item (failure to specify responsibility and review criteria necessary for contractor data packages) were identified in one area (Paragraph 5).
DETAILS 1.
Persons Contacted Washington Public Power Supply System (WPPSS)
- W. J. Talbott, Project Division Manager
- C. E. Love, Deputy Project Division Manager
- 0. E. Trapp, Project Engineering Manager
- J. C. Lockhart, Project QA Manager
- D. H. Walker, Principal QA Engineer
- L. E. Nilsen, QA Engineer
- P. J. Hannaway, Manager of Projects
- D. L. Guamme, Manager of Construction
- A. M. Cutrona, Senior Project Quality Engineer G. P. Zerbst, OC Engineer
- J. P. Sluka, Manager of Engineering
- C. B. Tatum, Senior Resident Engineer
- J. R. Sowers, Senior Project Quality Engineer
- L. F. Adams, QA Engineer
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W. K. Flint, Construction Engineer M. Shannon, Construction Engineer T. Bordeaux, Civil Contruction Engineer T. E. Cottrell, Resident Engineer - Field F. E. Shack, QC Engineer Pittsburgh Testina Laboratory (PTL)
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P,. Tallent, Site Manager D. A. Perry, Assistant Corporation QA Manager L. Young, Assistant Site Manager W. K. Barbour, Level II Technician S. McKay, Corporate QA Manager Guy G. Atkinson (GFA)
D. G. Summers, QC Supervisor State of Washington
- G. Hanson, Engineer (EFSEC)
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- Denotes attendance at Exit Interviews of December 8 and 21,1978.
- Denotes attendance at Exit Interview of December 21,1978, only.
2.
General A special inspection of the WriP 3/5 facility was conducted to determine and assess the adequacy of WPPSS corrective actions as a result of the discrepant conditions observed at the onsite Pittsburgh Testing Laboratory.
Pursuant to this purpose, the inspectors examined ti.e
'ety related implications of the PTL discrepancies and the ansee's action in response to an Imediate Action Letter issueo of the fiRC (Region V) on November 27, 1978.
3.
Imediate Action Letter Compliance It was determined that all Level I PTL personnel performing concrete inspection activities were recertified. Discussions with WPPSS and Ebasco personnel and review of surveillance documenN tion verified that the recertification was performed under the sur eillance of an Ebasco Level III inspector and did include an oral examination by that Level III inspector. The licensee had also required that PTL Level II inspectors be recertified by the same process.
Examination of PTL personnel qualification documentation verified that the re-certification program was being properly documented.
In addition, Level III personnel indicated that the ability of the PTL technician to perform a particular test was verified by observation of test performance for about 50% of the PTL technicians recertified.
Examination of test equipment ca.libration documentation verified that all test equipment, except that previously calibrated by an offsite organization, had been recalibrated and the results of the calibration appeared to be properly documented.
Discussions with licensee personnel and examination of applicable records revealed that the licensee had implemented adequate meas-ures to ensure that only certified personnel and calibrated test equipment were useu on all concrete placement testing activities for those placements made subsequent to the initial identification of the problem.
The PTL site manager, under whose auspices the discrepant conditions occurred, was relieved of all onsite duties on November 17, 1978. A letter from licensee management to PTL
-3-management on November 22, 1978, specifically required that the PTL individual concerned would not work on any NNP 3/5 activities in an on or offsite capacity.
PTL subsequently notified WNP 3/5 management that the individual concerned was no longer attached to the PTL Seattle District office.
PTL had assigned a new manager, with prior nuclear experience, to the site.
4.
Licensee Investigation and Corrective Actions The licensee conducted an investigation of the allegations made regarding PTL onsite activities (personnel certification and test report falsification) during the period of November 16-28, 1978, and issued a final report on November 30, 1978. The inspectors reviewed the report, with its recommended corrective actions, and concluded that the WPPSS investigation adequately addressed and assessed the PTL discrepant situations.
The inspectors based their assessment on ext.mination of PTL documentation and inter-views with PTL and licensee personnel.
The Division Manager on December 5,1978, assigned the corrective action responsibilities listed below:
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a.
Requalification of PTL site technicians under Owner / Engineer surveillance and recalibration of PTL test equipment used onsite. The NRC inspectors verified that this had been completed (see Paragraph 3).
b.
Review of PTL test records and full completion of concrete and soils test records.
c.
Ebasco Engineering evaluation of the effects / consequences of:
(1) Any test equipment found out-of-calibration.
(2) Any PTL test records found incomplete or improper.
(3) Any tests performed on Class I concrete or design mix verifications by uncertified technicians or uncalibrated test equipment.
d.
Review / revision of PTL certification and training programs.
e.
Development of a preventive maintenance / equipment repair program.
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Increased frequency of PTL Corporate QA audits.
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PTL submittal of all test recorJs to the project within one week of record generation.
The results of the above evaluations and corrective action implementations will be examined during a subsequent inspection.
(50-508/78-09-01)
5.
Structural Concrete a.
Review of Ouality Assurance Implementing Procedures The following quality assurance implementing docunents were examined for compliance with applicable PSAR, specification and ASTM requirements.
(1) Specification 3240-216:
" Technical Specification for Formed Concrete Construction" (2) GFA QCP-9:
" Concrete Preplacement Inspection" (3) GFA QCP-ll:
" Concrete Placement and Finish of Uniformed Surfaces" (4) GFA Field Instruction No. FI-1:
" Concrete Cold Joints, General Instruction" (5) Ebasco Procedure ASP III-4.12:
" Concrete Management and Control" (6) Ebasco Procedure IP-ll:
" Engineer Construction Surveillance and Verification of Civil Test Laboratory Contractor Surveillance" (7) Specification 3240-204:
" Inspection and Testing Services" (8) Ebasco Procedure QAI-6:
" Control of Nonconformances" (9) Ebasco Procedure ASP III-6.4:
" Processing of Nonconformances, Discrepancy Reports and Audit Findings" The licensee had previously identified that Procedure ASP III-4.12 (Concrete Management and Control) did not properly implement the requirements of ASTM C-172 (Sampling Fresh Concrete) in that
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-5-samples were allowed to be taken from the first part of a load being discharged and two slumps in sequence were to be taken from the same sample in the event that the first dump failed.
Since ASTM C-172 requires starting of tests within 5 minutes of completing the sampling activity, the inspector questioned the ability to perform three sequential slumps from the same sample within 5 minutes.
The inspector noted that ASTM C-94 (Ready Mixed Concrete) allows one check test in the event that slump or air content fall outside of specified limits. The licensee stated that the procedure would be revised to properly reflect ASTM requirements.
The revised procedure will be examined during a future NRC inspection.
In addition, the inspector noted that Engineering Department procedure ASP III-6.4 had not been approved by WPPSS or Ebasco personnel.
The procedure had been written for draft on September 9,1978.
The licensee committed to issuance and implementation of this procedure by January 15, 1979.
(50-508/78-09-02)
Discussions with licensee personnel indicated that Ebasco has no procedure which addresses the review responsibility and criteria necessary for approval of contractor submitted docu-ment packages.
In addition, apparently no procedure exists which requires traceability of Ebasco nonconformance reports to discrepancies identified by testing laboratory reports.
Licensee personnel stated that such a procedure would be written and implemented. This is an unresolved item.
(50-508/78-09-03)
Ebasco Procedure IP-11(Engineer Construction Surveillance and Verification of Civil Test Laboratory Contractor Surveillances) re-quires, in Paragraph 6.7, that, "All inspection and test records generated by the Civil Test Laboratory Contractor shall be re-viewed by the contractor and submitted to Ebasco Services, Inc.,
on a routine basis as required by Contract 3240-204.
Specification 3240-204, Rev.1 (Inspection and Testing Services),
requires, in Paragraph 8.4 of Section 2A, that certified copies of test reports covering all shop tests performed by the con-tractor be submitted after contract award. Contrary to the above, data sheets for PTL perfomed tests of " Time of Setting of Concrete Mixtures by Penetration Resistance" (ASTM C-403)
had not been submitted to Ebasco for review since May,1978.
This is an item of noncompliance.
(50-508/78-09-04)
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Observation of Work y
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The activities associated with concrete )lacement BMS-009-335 a
in the Unit 3 basemat were observed by tie inspector.
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activities included preplacement cleanup, reinforcing steel place-ment, review of the Concrete Placement Card, placing of con-crete, consolidation, and testing of fresh concrete.
During the placing of concrete, the inspector noted that concrete was
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being flowed greater than the five feet allowed by procedure and
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concrete was being placed over free water approximately one-half
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to three-quarters inch in depth. The Ebasco DC engineer at the placement stopped the above activities until corrective action
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was taken by removing the free water and instructing the fore-man on the five foot limit for flowing fresh concrete. The flow-ing of fresh concrete using vibrators also resulted in an unsystematic method of consolidating the concrete.
The vibrators (
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amount of time, but there was no systematic approach to the con-solidation other than melting down the pile of concrete and a
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vibrating areas that were in the vicinity of the pile.
In several
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instances certain areas appeared to have been left unconsolidated.
The GFA QC inspector instructed the vibrator operators which re-
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sulted in noticeably improved consolidation.
The testing of fresh concrete was observed on several occasions.
The tests for slump, air content by the pressure method, tempera-
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ture, unit weight, and the making of cylinders were performed by
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qualified personnel using calibrated equipment. All pertinent test data was being recorded by the testing technicians.
No items of noncompliance or deviations were noted.
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c.
Review of Quality Records
The concrete testing records for placements BMS-008-335 (started November 17, 1978) and BMS-006-335 (started November 27,1978) were g
reviewed to verify certain findings of the WPPSS investigation of
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Pittsburgh Testing Laboratory activities. The testing records of both placements had been partially or totally recopied. The prac-a tice of recopying made it extremely difficult in some instances
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for the inspectors to determine which sheets were originals and
which were recopies. As a result of the transcribing, information a
contained on the originals was not transcribed to the recopy.
In
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addition, data or remarks recorded on the truck trip tickets were not entered on the test sheets. Test acceptance criteria for
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slump, air and temperature were not entered on pages 1-5,10 and
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12 for placement BMS-006-335. Also, pages 7, 8, 9,10,11 and 12
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were not signed by the technicians lerforming the tests. These findings were generally identified by the WPPSS investigation.
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-7-The calibration records for equipment used in placement BrtS-008-335 were examined. The records for unit weight bucket serial number 9990 used in the placement could not be found (Unit Weight is not an acceptance test). The records for ther-mometer 419, also uscd in placement BMS-008-335 on ilovember 17, 1978, indicated that the themometer was lost on October 10, 1978.
Further inquiry revealed that another thermometer had been mistakenly assigned the same number. This error was identi-fied on December 4, 1978, during recalibration. The thermometer was then assigned number 419R. This new number had not been recorded on the. 41. records for the placement. The inspector determined that the conditionsnoted would have no adverse affect on plant safety.
The qualification records for the technicians who conducted the tests and the Level II that reviewed placement BilS-008-335 were examined.
The qualification records of the Level II indicated that he was not qualified for air content by the pressure method or making and curing concrete specimens in the field.
On flovember 22, 1978, as a result of the WPPSS Investigation, the complete recertification of personnel and recalibration of test equipment prior to further use in placements was started by PTL. A review of the personnel certifications and equipment calibrations for personnel and equipment used in placement BMS-006-335 verified that the recertification and recalibration had been accomplished prior to further use.
In general, it appears that the findings of the UPPSS investigations with regard to concrete testing records has been verified. Due to the numerous errors and deficiencies in the testing records, pTL committed to review all concrete testing records to date and docu-ment any deficient items on ?!CRs, as appropriate.
During the continuation of the inspection on December 18-21, 1978, the inspector reviewed the Field Test and Inspection Reports for the first two placements, BMS-007-335 and BMS-015-335, to deter-mine completeness of review.
These two placements had been reviewed by PTL and were ready for transmittal to Ebasco engineering.
In several cases, the truck ticket data did not agree with the Field Testing Inspection Report (FTIR). Ticket 0542 slump was 4 h inches and the FTIR stated 4 h inches (specifications allow 1-5 inch slump).
Ticket 0648 unit weight was 10 61 while the Field Testing Inspec-tion Report listed 151.09.
A;l o the above data was within spec 1-fication limits. The calibration of unit weight buckets SE 120 and SE 121 appeared questionable.
Both of the buckets were cali-brated on September 19, 1978. The calibration sheets dated September 19, 1978, did not indicate that a micrometer or dial indicator was used although measurements of the bucket dimensions
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For SE 120 on September 19, the wall thickness varied between.30 and.32 inches, whereas, on November 22, 1978, the wall thickness was recorded as being between.375 and.428. Approx-imately the same differences existed between the calibrations of SE 121 on September 19, 1978, and flovember 30, 1978. The calibra-tion of unit weight buckets will be reviewed during future inspec-tions.
The licensee stated that the discrepancy would be resolved.
The certifications of technicians used during placements BMS-007-335 on September 20, 1978, and BMS-015-335 on October 13, 1978, in Unit 3 were reviewed. One Level II used on BMS-007-335 was not qualified for sampling fresh concrete and one Level I used on place-ment BMS-015-335 was not qualified to make cylinders.
The lack of certification of testing technicians had been previously identified and an item of noncompliance issued in IE Inspection Report No.
78-508/78-08.
The results of the testing (slump, air, tempera-ture, cylinder strength) performed by the above unqualified personnel were comparable to the results obtained by qualified technicians.
Compressive strengths of cylinders were well in excess of design requirements. The inspectors had no further questions.
The following quality related records were sampled and examined for compliance with ASTM, PSAR, specification and procedural requirements:
(1) PTL test records of Initial and Final Set of Concrete perfonned, as required by ASTM C-403, during pericd of June through August of 1978.
(2) PTL test records of Sieve or Screen Analysis of Fine and Coarse Aggregate performed, as required by ASTM C-136, during period of August and November,1978.
(3) Ebasco letter of October 19, 1978, approving the mix design of (4) below.
(4) Master mix test results for mix designs 5000.75N and R and 50001.5 N and R (5) Site concrete mixing water chemical analysis test results.
(6) Air entraining admixture qualification test report.
(7) Certified Material Test Report for cement.
(8) Aggregate test reports of scratch hardness, petrograpnic analysis and potential reactivity.
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It clas noted that the PTL forms for recording of Initial and Final Set of Concrete data did not contain blanks for all of the information required by ASTM C-403; a number of test records were not narked for acceptability or unacceptability and a number of tests had been performed by uncertified personnel. Some test reports for aggregate testing (ASTM C-136) indicated that the test had been performed or approved by uncertified personnel and one of those tests (performed August 5,1978) identified that 88% of a sample of 3/4 inch aggregate passed a 3/4" sieve (ASTM C-136 specifies an acceptability range of 90-100%). The performance of tests by uncertifie personnel was identified during a previous d
fiRC inspection (IE Investigation Report flo. 50-503/78-03). The licensee agreed to resolve the additional deficiencies noted and this resolut ton will be examined during a future inspection.
(50-503/78~09-05)
6.
Quality Asssrance Program Approval M Audits of PTL The %spector reviewed the Supplier Quality Program Evaluation of PTL conducted by Ebasco on April 15, 1977. The evaluation disclosed several itens requiring corrective action prior to approval. The above items had been properly resolved by Ebasco.
Audits 3/5-EQA-204-1 through 3/5-E0A-204-9 covering the time period from May 27, 1977 to August 24, 1978, were reviewed by the inspectors.
Audits 3/5-E0A-204-1, 5, 6 and 8 were surveillances of user's tests on rebar and not audits.
Only one audit, 3/5-E0A-204-4, titicd "PTL Field Lab QA Program and Facility Audit," appeared comprehensive and covered criteria such as instructions and procedures in depth.
The other audits were superficial in nature and did not cover specific criteria of the QA Manual.
Discussions with Ebasco personnel indicated that the audit program is being revised to require aulits of specific QA criteria. This item will be reviewed during future inspections.
(50-508/78-09-06)
Audit 3/5-EqA-204-3 contained a comment on Trial Mix temperature differences between Specification 204, Page 2A-9, Specification 411, Paragraph 13.01, and Specification 415, Table 1.
This comment was never resolved by any followup or specification change.
Ebasco per-sonnel stated that the specification would be revised to correct the temperature differences.
flo items of noncompliance or deviations were noted.
7.
Surveillance of PTL The surveillances of PTL from October 14, 1978, through December 9,1978, were reviewed. The reports included surveillance of testing, personnel
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-10-qualifications, monitoring of written exams and records of oral exams given by Ebasco Level III personnel, fio items of noncompliance or deviations were noted.
8.
Licensee Audits The licensee performed an in-depth audit (Audit No. 3/5-216-15) of GFA activities on December-12-14,1978, which identified 38 findings requir-ing corrective action. On December 15, 1978, a letter was issued to GFA management identifying five items requiring immediate corrective action.
WPPSS is following up those items on a continuing basis.
In addition, on December 18, 1978, WPPSS project management sent a letter to GFA corporate managenent identifying corrective actions needed to fully implenent the OA program and demanding immediate corrective action.
The resolution of UPPSS ideatified discrepancies will be examined during a future inspection.
(50-508/78-09-07)
9.
Unresolved Itens Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraph 5.a.
10. Exit Interview The inspectors net with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on December 8 and 21, 1978, and summarized the scope and findings of the inspection. The in-spectors discussed their concerns regarding the review of completed data packages submitted by contractors onsite and the licensee indi-catec that a procedure would be written) to specify the responsibility and criteria necessary for review of contractor submitted data packages.
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g Washington Public Power Supply System A JGINT OPERATING AGENCY P. O. 804122 3 elm A, W ASHINGTON 98541 PHONE {206] 249-5001
/TOSl%'4 Februarv 21, 1979 G03-79-255
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Nuclear Regulatory Commission 4::
Region V D
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1990 North California Boulevard W
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Attention:
G. S. Spencer, Chief Reactor Construction and Engineering Support Branch Subject:
HPPSS NUCLEAR PROJECTS 3 AND 5 NRC INSPECTION OF WNP-3 AND WNP-5 DOCKET NUMBERS 50-508 AND 50-509 Reference:
Letter, G. to N. O. Strand, same subject, dated January 16, 1979.
Dear Mr. Spencer:
The referenced letter transmitted the results of the inspection conducted by regional based inspectors during December 6-21, 1978 and which identi-fied an item not in full compliance with NRC requirements.
Our response to the " Notice of Violation" is contained in the attachment to this letter.
For your convenience we have restated the notice.
Should you have any questions or desire further information, please feel free to contact me directly.
Very truly yours, dCd.O D. L. RENBERGER Assistant Director, Technology Attachments cc: NRC-Office of Inspection and Enforcement D. Smithpeter - BPA
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NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of December 6-21, 1978, it appears that one of your activities was not conducted in full com-pliance with NRC requirements as indicated below. This item is a deficiency.
10CFR50, Appendix B, Criterion V, states, in part, that " Activities affecting quality...shall be accomplished in accordance with... instructions, procedures, or drawings."
Section 17.1.5 of the Quality Assurance Program documented in the PSAR states, in part, that, "The WPPSS QA Program Manual delineates the methods hy which WPPSS complies with the criteria of 10CFR50, Appendix B."
The WPPSS QA Program Manual procedure QAP-2, Paragraph 3.1, states that,
...the AE/CM's responsibilities... include developing and implementing its
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Quality Assurance Program, and the policies, procedures and/or instructions for implementation, based on the requirements delineated in the NCR's 10CFR50, Appendix B..." and the " Activities shall be accomplished in accordance with these policies, procedures and/or instructions."
EBASCO Procedure IP-ll, Engineer Construction Surveillance and Verification of Civil Test Laboratory Contractor Surveillcnces, states in Paragraph 6.7 that, "All inspection and test records generated by the Civil Test Laboratory Contractor shall be... submitted to EBASCO Services, Inc. on a routine basis as required hy Contract 3240-204."
Contract 3240-204, in Paragraph 8.4 of Section 2A, states that, " Certified copies of all test reports covering all shcp tests performed by the contractor be sub-mitted after contract award."
Contrary to the above, as of December 21, 1978, data sheets for tests performed by PTL since May, 1978,.of " Time of Setting of Concrete Mixtures hy Penetration Resistance" (ASTM C-403) had not been submitted to EBASCO.
RESOLUTION:
The data sheets for tests performed for " Time of Setting of Concrete Mixtures by Penetration Resistance" (ASTM C-403) were received by Ebasco on January 16, 1979.
These reports have now been reviewed by Ebasco.
ACTION TO PRECLUDE RECURRENCE:
PTL Procedure QC DC 1 is being revised to specify timely transmittal of reports.
PTL has committed to submit all on-site test reports within one (1) week of test completion.
DATE OF FULL COMPLIANCE:
PTL Procedure QC DC 1 is scheduled for approval by February 23, 1979.
Implementa-tion of the one week submittal requirement for test reports was established as of December 18, 1978.
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UNITED STATES g
NUCLEAR REGULATORY COMMisslON y
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REGION V
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1990 N. CALIFORNI A BC,ULEVARD o
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WALNUT C' EEK, C ALIFORNI A 94596 FEB 2 81979 Docket Hos. 50-508 50-509 Washington Public Power.- Supply System P. O. Box 468 Richland, Washington 99352 Attention: Mr. N. O. Strand Managing Director Gentlemen:
Thank ycu for yorr letter dated February 21, 1979 informing us of the steps you have taKen to correct the item which we brcught to your attention in our letter dated January 15, 1979.
Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely, hS~S 7eAll --
R. H. Engelken Director