IR 05000508/1981001
| ML20003E027 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 02/12/1981 |
| From: | Dodds R, Haist D, Hernandez G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20003E014 | List: |
| References | |
| 50-508-81-01, 50-508-81-1, 50-509-81-01, 50-509-81-1, NUDOCS 8104020111 | |
| Download: ML20003E027 (9) | |
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U. S. NUCLEAR REGUL\\ TORY C0!O!ISSION
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OFFICE OF INSPECTION AND ENFORFEMEh"r 50-508/81-01
REGION V
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Report No.
50-508 & 50-509 CPPR-154 & 155 Docket No..
License go, Sanges %
Washington Public Power Supply System Licensee:
P. G. Box 968
Richland, Washington 99352
' Facility Name:
WilP-3 and WilP-5
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WNP-3 and WNP-5 Site (Satsop)
Inspection at:
Inspection conducted:
January 13-16, 1981 Inspectors:
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'D. P.
aist, Reactor Inspector
/ nate Signed A. &&a%j sNet i
y Hernandez, p tor Inspector Date Signed Date Signed Approved 3y: f '7
[b c/M[/V R. T. Dodds, Chief, Engineering Support Section Ddte Signed
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Reactor Construction and Engineering Support Branch Summary:
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Inspection during the period of January 13-16, 1981 (Report Nos. 50-508/81-01 and 50-509/81-01)
Areas Inspected: Routine,. unannounced inspection by regional-based inspectors of construction activities including quality assurance program and implementing procedures of the prime civil / structural contractor inside the reactor containment and steel structures and supports by the containment and reactor auxiliary building contractors.
-The inspection involved 46 inspector-hours onsite by two NRC inspectors.
Results:
Of-the three areas inspected, one item of noncompliance was identified in the area of stud welding (paragraph 2).-
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RV Form 219 (2)
81'04020111
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DETAILS 1.
Persons Contacted
a.
Washington Public Power Supply System (WPPSS)
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- D. Dobson, Project Manager
- J. Puzauskas, Ouality Assurance Engineering Supervisor
- C. E. Love, Construction Manager
- 0. E. Trapp, Engineering Manager
- M. Monopoli, Quality Assurance Operations Supervisor b.
Ebasco Services Inc. (Ebasco)
- A. M. Cutrona, Quality Assurance Manager
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- R. G. Peck, Project Quality Assurance Engineer
- C. M. McClaskey, Project Quality Assurance Engineer
- L. F. Adams, Senior Project Quality Engineer
- J. Kovacs, Assistant Project Quality Assurance Manager
- J. C. Murphy, Project Superintendent
- T. E. Cottrell, Senior Resident Engineering
- J. P. Sluka, Manager of Engineering c.
Morrison-Knudsen, Inc. (M-K)
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G. Hill - Duality Control Manacar G. C. Rogstad - Lead Quality Control Engineer d.
0. Weil - Quality Assurance Superintendent D. R. Weinstein - Quality Assurance Engineer L. Barno - Project Manager
- Denotes those present at the NRC management meeting on January 16, 1981.
In addition Mr. G. Hansen, Senior Project Engineer and Mr. W. Fitch, Executive Secretary of the Washington Energy Facility Site Evaluation Council and Mr. J. A. Adams, Owner's Site Manager of Pacific Power and Light Company attended the meeting..The NRC Senior Resident Inspector also presented his inspection findings' at this meeting.
2.
Site Tour The inspectors conducted a tour of both units on January 14, 1981 to observe completed work and work in progress for obvious deviations or noncompliance with PSAR commitments..nd regula+ory requirements.
During the tour the inspectors examined stud welding activities on the south side of Unit No. 5 and noted the following:
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(1) A stud welding operator welding on a member between columns Nos. CA-12 and CA-13 had welded approximately cixty studs without bending the first two studs of the series as required by Morrison-Knudsen Administrative Instruction Number 15 ( AI-15),
" Stud Welding Inspection Procedure" which states in paragraph 6.3 that, "Each operator sgall bend the first two studs on each
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day's oduction to 30 and the first two studs on each member to 30 This procedural requirement, which is consistent with the requirements for stud welding in AWS Dl.1, is utilized as a production check to assure that if a failure were to occur in the weld zone of either stud, a procedure change would be initiated and then two more studs would be welded and tested.
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Discussions with the stud welding operator indicated that he was aware of the procedural requirement, but had forgotten in this instance to comply with the requirement. The operator then proceded to test the first two studs and they were found to be satisfactory.
(2) The inspector also noted that paragraph 6.8 of the same procedure (AI-15) requires that, "The operator shall circle with a paint stick, or paint a line up the shank of the first two studs bent on each new member". Contrary to this, discussions with the operator, craft foreman, and the quality control inspector indicated that the QC inspector, not the operator, had been markir: the studs.
This practice had been occurring for an indeterminate time in both Units 3 and 5.
Examination of the surrounding area (concrete placement No. 5 ABS-017-362.5) gave visual evidence of this procedural violation.
(3) Paragraph 6.5 of A.I.-15 states that, "All ferrules (the ceramic arc shield at the base of the stud) must be broken off by the operator prior to inspection." Examination of welded studs at concrete placement no. SABS-017-362.5 revealed numerous studs with parts of the ferrules still in place. These studs had been accepted by M-K quality control inspectors.
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The failure to accomplish work in accordance with quality procedures is considered on apparent item of noncompliance with 10 CFR 50, Appendix B Criterion V, Instructions, Procedures, and Drawings.
(50-508,509/81-01/01)
Subsequent to notification of the above f.adings the licensee issued a Corrective Action Report No. E003 on January 14, 1981 to address the programmatic deficiencies identified and on January 15,1981 the contractor (M-K) issued inter-office correspondence no.10C-81-52 addressing action taken with respect to the NRC findings. Contractor
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action taken included (1) a tt aining session with the applicable QC inspectors and construction personnel on M-K procedure A.I.-15; (2) M-K construction was informed to remove all ferrule material in placement no. ABS-017-362.50 prior to placing rebar; and (3) the M-K QC stud welding inspector who had inspected the studs in question was
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re-certified.
3.
Licensee Action on Previously Identified Followup and Unresolved Items a.
(0 pen) (50-508/509/80-06/04) Unresolved Item:
CBI-Controls for the Installation of Polar Crane Rail Systems In I.E. Inspection Report No. 80-06 the inspector questioned why
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the contractor had not generated procedures to assure that the non-welded assemblies of the crane rail have been properly installed and inspected (i.e. verification of proper materials, configuration, and bolting).
Since that time CBI has installed and performed the initial alignment of the Unit 3 crane rail with final alignment to take place when the polar crane is set in place. The polar crane is scheduled to be set on the weekend of January 17 and 18, 1981.
At this time, CBI has not generated any procedures or inspection documentation for either the Unit 3 or Unit 5 crane rails and associated components.
CBI contends that neither the contract specification nor the ASME Cede requires procedures or inspection documentation. The inspector was also informed that the crane rail.is an off-the-shelf item and is considered a WPPSS Quality Class G component.
Section 3.8.2.4.5 of the PSAR defines the four components that make up the crane girder as the rail, the upper and lower rings, the box beam and the vertical supports.
From this description it would appear that the crane rail should have the same quality designation as the other components of the crane girder.
Ebasco engineering personnel stated that the Ebasco New York office will research this item and present a justification for the quality classification of the crane rail. This item will continue to be unresolved until review of-that justification.
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(0 pen) Followup Item (50-508/509/80-15/02) - Policy for Documenting and Voiding of Inspection Documents An examination of J. A. Jones procedure No. P0P-N-707, " Site Inspection and Test" had disclosed that the QV supervisor reviews
' inspection reports for completeness and validity prior to adding the report number. and logging the report into the system. A review of procedure No. P0P-N-703, "Nonconformance Reporting". disclosed
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a similar procedure in that the nonconformance report is reviewed by the QV supervisor to verify, among other things, that the report actually constitutes a nonconforming condition prior to the logging and entry into the system. Apparently,
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if the QV supervisor feels that the condition is not a nonconformance, the report may be destoyed. The inspector pointed out that the system, as constituted, is not auditable or verifiable to assure that the QV supervisor's decisions were appropriate since no record of the determination or the basis for the determination would exit.
The licensee committed to evaluate these procedures and the procedures of other site contractors and take appropriate corrective action. This issue will be addressed in a subsequent inspection.
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4.
Safety Related Structures (Structural Steel and Supports) -
J. A. Jones - Contract No. 265 Review of Quality Assurance Implementing Procedures The inspector continued an examination of J. A. Jones quality assurance implementing procedures to ascertain whether quality assurance plans, instructions and procedures have been established-and whether these documents conform to PSAR commitments, industry standards, and design specifications. The following procedures were examined:
Procedure No.
Title P0P-N-709, Rev. 1 Project Quality Assurance Records
- P0P-N-710, Rev.1 Preliminary Evaluation of Bid Candidates P0P-N-711, Rev. 2 Supplier Evaluation P0P-N-712, Rev.1 Inspection of Incoming Material P0P-N-713, Rev. 1 Use of Discrepancy Reports P0P-N-714, Rev. 1 Corrective Action The Linspector identified the following concerns with the procedures reviewed:
(1) ANSI-N.45.2.9-1974, paragraph 4.3 specifies that a receipt control system shall be established for receipt and control of quality assurance records. The-following are minimum requirements of the receipt control system:
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A records check list designat4g the required quality assurance records.
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A record of quality assurance' records received.
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. Procedures for receipt.and inspection ofl incoming records.
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These requirements are also specified as applicable to contractors in paragraph 5.17 of Ebasco Specification No. 860-W, Rev. 2,
" Contractor Quality Assurance Requirements Quality Class I Activities."
These requirements do not appear to be reflected in either procedure No. P0P-N-709, Rev.1 " Project Quality Assurance Records" or procedure No. QAI-001, Rev.1, " Quality Assurance Documentation, Records System
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and Controls."
(2) ANSI N45.2.9-1974, paragraph 3.2.1 states that quality assurance records shall be considered valid only if stamped, initialed, signed, or otherwise authenticated and dated by authorized personnel.
This requirement is also specified in Ebasco Specification No. 860-W, Rev. 2, paragraph 5.17.
These requirements are not, however, specified in the contractor's procedure No. P0P-N-709, Rev. 1.
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(3) ANSI N45.2.9-1974, paragraph 5.7 specifies minimum audit requirements
for the records storage system. These minimum audit requirements are not specificd in the controlling specification No. 3240-265 Section 2A nor the supplemental specification No. 860-W. These requirements are also not incorporated in the contractor's procedure Nos. P0P-N-705, Rev.1 " Project Quality Assurance Records or POP-N-708, " Quality
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Assurance Audits".
(4) Ebasco Specification No. 860-W, Rev. 2, paragraph 5.17 specifies the requirements for alteri_ng quality assurance records.
These requirements have not been incorporated into contractor procedure No. P0P-N-709, Rev.1 "Pr oject Quality Assurance Records".
(5) Ebasco Specification No. 860-W, Rcy. 2, paragraph 5.7 specifies that " Subcontractor's Quality Assurance Programs must be reviewed and approved by the contractor, by personnel qualified and knowledgeable in Quality Assurance"...and " Objective evidence shall be available which substantiates the acceptance of a supplier as an acceptable source of equipment, materials or services".
Centractor procedure No. P0P-N-711, Rev. 2, " Supplier Evaluatior.",
paragraph 3.2 defines the supplier evaluation team as..." consist of one or more Quality Assurance Personnel who may be assisted by Engineering and/or Purchasing Personnel." The qualifications or expertise required of these evaluation personnel are not specified.
The evaluation team uses a supplier evaluation report to evaluate a potential supplier's quality assurance program. The procedure specifies no criteria for acceptance of a supplier and does not
. define the term " conditionally accept" on the evaluation checklist.
The inspector did'not verify whether or not the aforementioned procedure deficiencies exist in the contractors actual work methods so.the' failure of these additional contractor procedures to incorporate specification requirements-is considered unresolved (50-508/509/81-01/02).
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5.
Project Review of Contractor Submittals As a result of deficiencies in the contract No. 265 procedures (Ref. IE Inspection Report No. 50-508,509/80-15 and paragraph 4 of this report) and the failure of other contract procedures to adequately
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incorporate specification requirements (Ref. IE Inspection Report Item No. 50-509/79-08/02 - Contract No. 213) and the requirements of administrative site procedures (Ref. IE Inspector Report Item No. 50-508/79-08/01-Contract No. 251) the inspector requested a sampling of the following procedures and the applicable review cycles by various project groups:
Contract No.
Procedure No. and Title Mandatory Review Groups Comments 251 PKS-WI-302, Rev.1 -
Quality Assurance Yes
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Field Erection and Resident Engineering Yes and Handling Pipe Ebasco Site Support Yes Cleanliness Instruction Engineering Contract Team Yes 251 PKS-EP-9, Rev. 0 -
Quality Assurance Yes Packaging, Shipping -
Prepurchase Contrack No Receiving,. Storage &
Handling Items for Nuclear Power Plants 251 PKS-CP-7, Rev. 0 -
Quality Assurance Yes General Welding Procedure Ebasco Site Support Yes Engineering 265 WE-SP-102, Rev. 0 -
Quality Assurance Yes Structural Welding Resident Engineering No Procedure-Ebascc Site Support Yes Engineering
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265 WE-WP-11, Rev. 2 - Weld Quality Assurance Yes
' Filler Metal Control Ebasco Site Support No Engineering 265 WE-WP-12, Rev. 0 -
Quality Assurance Yes Drilled-In Expansion Resident Engineering Yes Type Anchors 265-WE-WP-12, ~ Rev. 1 -
Quality Assurance No Drilled-In Expansion Resident Engineering Yes Type Anchors Ebasco Site Support-Yes Engineering
.225 CP-403S3, Rev. 0 Quality Assurance Yes Construction Procedure Ebasco Site Support Yes for Welding of Steel Engineering Structures 263 AI-07-WPPSS,' Rev. 3, Ebasco Site Support Yes
. Welding Material'
Engineering
' Control Procedure:
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i The review of this sampling indicates that the major contractor submittal review efforts are being undertaken by the quality assurance organization. Quality assurance reviews frequently result in extensive comments (Ref. Procedure Nos. PKS-EP-9, PKS-CP-7) or rejection and total revision of the procedure for the contractor
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(Ref. Procedure PKS-WI-302). Quality assurance reviews have alsc resulted in extensive engineering and code compliance comments (Ref Procedure WE-SP-102).
Administrative site procedure No. ASP-RE-2-4 Rev. 2 " Construction Contract Document Submittals", governs the review of contractor submittals. Paragraph 3.3.2 specifies that the submittal reviewer
" Performs thorough review of submittals in regard to department responsibilities.
For example: Quality Assurance reviews submittals
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for QA requirements." No other specific guidance is provided to submittal reviewers. The inspector surveyed the quality assurance, resident engineering, and Ebasco site support engineering groups to determine what specific guidance is provided to persons performing reviews of contractor submittals. Quality assurance review of contractor submittals is governed by quality assurance instruction Nos. QAI-7-1, Revision 1, " Quality Assurance Review of Contractor Quality Assurance / Quality Control Programs" and QAl-7-2, Revision 3,
" Quality Assurance Review of Contractor quality Affecting Procedures".
j Procedure QAI-7-2, in particular, describes the specific retiew criteria that must be followed by the reviewer. The resident engineering and Ebasco site support engineering groups provide no specific guidance to their reviewers which may explain why the quality assurance reviews, although not totally effective, appear to be more intensive than those of other review groups. The resident engineer committed to examine the need for guidance for reviewing contractor submittals.
No other commitments in this regard were forthcoming from the licensee. The
- adequacy of review of contractor submittals is considered unresolved (50-508/509/81-01/03).
6.
Stru'ctural Concrete Review of Quality Assurance Implementing Procedures The following quality assurance procedures for the two civil contractors performing' quality class I work were reviewed to assure compliance with
- the applicable' contract specifications, the ACI codes, and the PSAR:
- Contractor:
' Procedure
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.Morrison-Knudsen CP 01, Concrete placing, curing, finishing and inspection J. A."JonesL-WE-WP-5, Concrete placing, curing, finishing
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and inspection
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During this examination the inspector reviewed a memorandum dated December 11, 1980 (No. 3240-263, 265) which indicated that fi-K and J. A. _ Jones were not in compliance with the requirements of ACI-306-66
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for cold weather concrete operations.
Specifically, ACI-3Lv in paragraph 8.1, states in part "The record should include temperatures at several points within the enclosure and on the concrete surface, corners, edges in sufficient number to show highest and lowest temperatures of the concrete.... Maximum and minimum temperature readings in each 24-hour period should be recorded. Data recorded should clearly show the temperature history of each part of the concrete."
Contrary to this, M-K's inspection personnel record two ambient enclosure temperatures each day at one point within the enclosure.
They do not
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record the time the temperatures are taken.
J. A. Jones' inspection personnel record one ambient enclosure temperature each day at one point within the enclosure. They also do not record the time the temperatures are taken.
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The memorandum also requests that the contractors initiate action to assure that they are in compliance _with ACI-306 and during a meeting on January 15, 1981 the inspector was assured by licensee representatives that both. contractors are currently acting on this request.
This item will remain unresolved pending a future inspection to review the programmatic changes to and the implementation of the respective procedures _with the requirements.of ACI-306.
(508/509/81-01/04)
7.
Unresolved Items
~ Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved items disclosed during the inspection are discussed in paragraphs 4, 5 and 6.
8.
Management Meeting The inspectces met with the licensee and engineering management denoted in paragraph 1 at the conclusion of the inspection on January 16, 1981.
- TneL nspectors. discussed the scope and findings of the inspection.
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i The inspectors expressed concern that the lessons being learned at the WNP-2 facility with regard to allowing the QC Supervisor to decide the
' validity of inspection findings or nonconformances prior to logging the finding into the system have not been implemented at the WNP-3/5 facility.
The 1.icensee.' acknowledged this concern.
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