IR 05000508/1981002
| ML19345H502 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 03/13/1981 |
| From: | Bishop T, Dodds R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345H499 | List: |
| References | |
| 50-508-81-02, 50-508-81-2, 50-509-81-02, 50-509-81-2, NUDOCS 8105210021 | |
| Download: ML19345H502 (11) | |
Text
4
'.
U. S.' NUCLEAR RECUIATORY C0!ciISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
50-508/81-02 Raport No. 50-509/81-02
-
Do'cket No. 50-508, 50-509 License No. CPPR-154, -155 safeguards croup Licensee:
Washington Public Power Supply System P. O. Box 1223 Elma, Washington 98541 Facility Name: Washington Nuclear Projects Nos. 3/5 (WNP-3/5)
Inspection at: WNP-3/5 Site, Elma, Washington Inspection conducted: January 5-30, 1981 4tM h 3.ggf Inspectors:
/ /te Signed T. W. fishop[Sr. Resident Inspector D
.
Date Signed Date Signed
.
Approved By:
/]
[
R. T. Dodds, Chie f
'Datd signed Reactor Construction Project Section 2 Insoection during the period of January 5-30, 1981 (Report Nos. 50-508/81-02 and 50-509/81-02)
'
Areas Inspected _: Routine, unannounced inspection by the resident inspector
- of construction activities including: containment post weld heat treatment quality implementing procedures, work activities, and review of quality records; safety related pipe support systems; structural steel bolting quality implementing procedures, work activities, and review of quality records; concrete batch plant operations; concrete testing; investigation of aUegations relating close out of nonconformance reports; and followup on prcvious inspection findings.
The inspection involved 73 inspection hours onsjte by one NRC Inspector.
Results: Of the eleven areas inspected four items of noncompliance were identified as follows: failure to' establish measures to control inspection status, paragraph 2.a; failure to properly perform structural steel bolting inspections, paragraph 3.b; failure to incorporate proper inspection criteria into QA procedures, paragraph 3.a; and failure to maintain adequate records of inspection activities, paragraph 3.c.
RV Form 219 (2)
.
8105210042/,#
.
. _..
- -
... - -
._
_
,
_
.
_
_,.
_-
-.
-
. -.
.
.
--
.
.
.
.
,
DETAILS 1.
Persons Contacted The inspector interviewed various engineering, management, inspection and construction personnel of the organizations listed below.
Key personnel
- including those who attended the exit interview are specifically identified below, a.
Washington Public Power Supply System (WPPSS)
- D. E. Dobson, Project Manager, WNP-3/5
- J. C. Lockhart, Project Quality Assuran : Manager C. E. Love, Construction Manager 0. E. Trapp, Engineering Manager
- J. A. Puzauskas, Quality Assurance Engineering Supervisor M. Monopoli, Quality Assurance Operations Supervisor J. M. Walker, Sr. Project Quality Engineer T. Letchford, Sr. Project Quality Engineer b.
Ebasco Services, Inc. (Ebasco)
J. P. Sluka, Manager of Engireering
- A. M. Cutrona, Deputy Project Quality Assurance Manager
- J. C. Murphy, Project Superintend >'t L. F. Adams, Sr. Project Quality ineer L. A. Bast, Project Quality Engit e
C. M. McClaskey, Le6d Project Quality Engineer T. E. Cottrell, Sr. Resident Engineer R. G. Peck, Project Quality Engineer c.
Morrison-Knudsen, Inc. (MK)
i R. Davis, Quality Manager G. Hill, Quality Control Manager d.
Associated Sand and Gravel (ASG)
A. Demers, Project Manager B. Habnitz, Corporate Quality Assurance Manager e.
Pittsburgh Testino Laboratories (PTL)
J. Adachi, Technical and Administrative Manager T. Gibbs, Resident Quality Assurance Representative
-
l
.
_
_ _
..__
_
_
_
.
-_
_
__
.
'
.
,
.
f-2-f.
Chicaco Bridge and Iron, (CBI)
P. Van Niel, Construction Welding & Quality Assurance Manager 0. Wein, Project Welding & Quality Assurance Superintendent g.
Other W. L. Fitch, Executive Secretary, Washington Energy Facility Site Evaluaden Council G. Hansen, Chh:f, Operations Division, Washington Energy Facility Site Evaluation Council J. A. Adams, Owners Site Manager, Pacific Power and Light Denotes those preset at the NRC management meeting on January 30, 1981.
- 2.
Licensee Action on Previous Inspection Findings a.
(0 pen) 50-508/509/80-06-02, Noncompliance - Failure to Establish Measures to Indicate Inspection Stalq'(3 (MK)
The licensee's response to the item of noncompliance is documented in WPPSS letter No. G03-80-2364 of September 26, 1980. The actions taken included proper rebolting of the structural steel joint in question; additional training of cognizant inspection personnel; and procedural changes to require as-built drawings of all structural steel connections. The inspector previously verified that the specific
-
joint in question had been properly rebolted and that procedural changes and training)had been accomplished (see NRC inspaction report No. 50-508/509/80-13.
,
As noted in NRC inspection report No. 50-500/509/80-13 the licensee's I
comitted action of developing as-built drawings for all structural steel connections had not been fully accomplished by October 30, 1980 and provisions had not been initiated by the contractor to
,
I fully meet all of this comittment (i.e. to develop some means to I
assure all previously accortplished work had received the proper I
inspection).
Examination of this area during the current inspection l
revealed that:
(1) No formal requirements had yet been established by the licensee or the contractor to assure that all structural joints erected before July 11, 1980 had received the proper inspection.
It was determined, however, that bolting inspectors for Unit 3 were developing as-built drawings for previously complete
!
work, as time allowed.
,
(2) The requirement for developing as-built drawings to control inspection status had not been formally implemented for welded l
structural joints. The contractor's Quality Control Level III l
welding inspector had not interpreted the new procedural requirements
!
for developing as-built drawings as applicable to welded joints, although he had developed some unofficial as-built-type drawings.
l
.
.
.
.
3-
-
To 6ssess the adequacy of those as-built drawings that had been developed for previously completed work the inspector selected the following Unit 3 structural steel joints at random for documented beam 24A to evidence of satisfactory quality (control inspection: bolted); beam 25A to 22 227A (bolted); beam 24B to 226D beam 226Dto2288(bolted); beam 212Ato215B(bolted); beam 228B to 201A (bolted); beam 201A to 236C (bolted); beam 236C to 227A
'
(bolted); beam 235E to wall clip (bolted); beam 237F to wall clip l
(bolted); beam 235E clip to embed (welded); and beam 237F clip to embed (welded). Completed quality control inspection record forms were available for eleven of the twelve joints selected.
Investigation into the lack of a quality control inspection record for the remain'ng joint (welded connection of beam 237F to the embed plate) revealed that no inspection report had been generated for the connection which was made in April 1980. Other records (structural steel check list) show that this structural steel was accepted by the contractor on April 28, 1980. This is contrary to the requirements of the contractor's inspection procedure no. AI-14 and 10 CFR 50, Appendix B, Criterion V.
This is an apparent item of noncompliance.
Additional areas of concern relating to bolting were identified during the current inspection. These areas are addressed in paragraph 3 of this report, b.
(0 pen) 50-508/509/80-13-01, Noncompliance - Failure to Assure Structural Steel Bolted Assemblies are Erected in Accordance with Specification Requirements.
The licensee's response to the Notice of Violation was sumarized in WPPSS letter no. G03-81-054, of January 9,1981. The letter indicated that the specific joints that were improperly assembled had been corrected and that the cause was attributed to craft personnel loosening the joint after quality control acceptance. To correct l
this problem in the future, an Interim Procedure Change Notice (IPCN) was issued to procedure CP-05, requiring notification to quality control if previously accepted connections are to be reworked.
The letter furthar stated that training classes were provided on procedure CP-05 and that additional quality control inspectors had been assigned.
.
Full compliance was stated as having been achieved by November 1, 1980.
The inspector verified that the specific joints had been properly corrected.
Examination of the IPCN (number 94) and the training records disclosed an inconsistency with the full compliance date of Movember 1,1980.
The IPCN was not issued for use until January 7,1981 and the training
-
e ns
- - - -.
e n
+
,--
,nn.-
, -
,--.-g.
-s
~
.--
,m--
--,-,--,s---y-a,-
---e-
e----4 r---
._-
.
'
.
.
-4-
.
pertained to a subject other than loostning of bolts (i.e. as-built drawings).
It was also determined that only one bolting inspector had been assigned, and that he was not hired until January 5,1981.
Because of the inconsistencies between the statements in the letter and the conditions observed by the inspector an investigation was initiated on January 22, 1981. The results of the investigation will be addressed in a separate report. The licensee's action regarding the item of noncompliance will be further examined following complM Mn of the investigation.
c.
(Oper.) 50-508/509/80-09-04 Noncompliance - Failure to Smcify the Correct Equipment Quality Classification in Procurement Documents.
The licensee's response to the item of noncompliance is documented in WPPSS letter no. G03-80-2966 of November 21, 1980. The actions taken included a review of the contract specification in question (no. 3240-251), and correction of the improper quality classification designations. The letter further stated all WNP-3/5 contracts involving owner-furnished equipment would be reviewed by Ebasco engir.eering, by January 15, 1981, to assure consistency with PSAR quality classification designations. The inspector verified that the review of the 3240-251 contract had been completed and the improner quality class designations corrected. Licensee action to review other pertinent contracts had not been completed. As of January 30, 1981 only one other contract had been reviewed (no.
,
3240-224).
Licensee representatives stated that the remaining contracts would be reviewed in an expedient manner. Subsequent to the inspection, on February 9,1981 the licensee issued letter t
l No. G03-81-386 to the NRC Region V stating that the reviews would be completed by February 17, 1981. This item remains open pending satisfactory completion of the licensee reviews.
The licensee's Quality Assurance Manual (section QAP-3) addresses the development of a quality classification list and provides controls for controlling changes in quality classification for items and services at the project.
From discussions held with licensee representatives during the inspection period it was not clear whether such a list had been fully developed for the project. Accordingly, this item is unresolved and will be examined in the next inspection (508/509/81-02-02).
d.
(Closed) 50-508/509/80-09-01, Unresolved Item - Concrete batch plant inspection practices Associated Sand & Gravel cement silo / bin and mix water visual inspection techniques were reviewed with contractor representatives. View ports have been installed in the cement containers and water quality visual inspections are now performed at a more direct location.
The results of inspections for the past four months were examined and found satisfactory. The inspector has no further questions on this matter.
. -
- - - -.
-
.
. _ _ _
-
..
. - - _
-
.
-5-e.
(Closed) 50-508/509/80-13-03, Followup Item - Allegations regarding receiving inspection activities.
In October 1980 an individual contacted the NRC regarding allegations which he had also made to the Incensee. These were:
(1) The WPPSS/EBASCO material receiving organization recently received a shipment of 13 bolts (approximately 1-1/8 inch in diameter) with accompanying documentation which addressed only 12 of the 13 bolts.
Rather than fill out an " overage" report, as required by the procedures, the quality control inspector directed that the excess bolt be discarded (reportedly to save paper work).
(2) A defective beam received at the site was repaired by a site contractor whereas the supporting documentation for the repair indicates the beam was returned to the supplier for repair (hearsay).
The report t,f the licensee's investigation of these allegations, completed in January 1981, found the first allegation to be substantiated (but of no safety concern) and the second allegation to be unsubstantiated. To eliminate any question regarding the repaired beam, the licensee subjected the beam to additional nondestructive examination and found it to be satisfactory. NRC interviews with the individuals involved confirmed the findings of the licensee's
'
investigation and completion of corrective actions (reinstruction of personnel) to preclude a recurrence of the apparent disregard for completion of overage reports. The inspector has no further questions on this matter.
3.
Safety Related Structural Ste31 l
a.
Quality Assurance Imolementing Procedures The inspector reviewed Contract 3240-263 procedure no. CP-05, revision 5 (cntitled " Structural Steel Erection Quality Class I, II, and G),
for aspects relating to high strength bolting activities. These areas of the procedure were examined for compliance to the requirements of the AISC Steel Construction Manual, the Specification for Structural Joints Using ASTM A325 and A490 Bolts, the contract specifications (nos. 3240-263, 501-Wa, and 448), ANSI N45.2.5, and the PSAR.
The review identified that the scope of inspection specified in the procedure CP-05 was significantly less than the scope of inspection required by Specification 3230-501Wa, the Specification for Structural Joints Using ASTM A325 and A490 Bolts, and ANSI N45.2.5. Whereas paragraphs 8.4 and 9.5.4 of procedure CP-05 call for 20% or two bolts in each connection to be examined for such things as use of washers, proper bolt size, length, grade, and thread engagement, the controlling documents require 100% inspection for these attributes.
Utilization of a sampling procedure contrary to the aforementioned
,
'
i requirements is considered to be an apparent item of noncompliance with 10 CFR 50, Appendix B Criterion V (50-508/509/81-02-03).
.
-
_
.-
_ _ - _
,_.
_
___
__
'
.
.
.
-6-b.
Observations of Work and Work Activities The inspector selected 15 structural steel bolted joints in the Unit 5 reactor auxiliary building and 5 joints in the Unit 3 auxiliary building for examination. The work was inspected for compliance to drawings (Fought Nos. E-11 and E-13), and the procedures and specifications identified in paragraph 3.a. above.
Inspection reports and quality records on file with the contractor stated that each of the twenty joints examined had been inspected and accepted by the contractor's quality control staff. The examination of the structures identified one joint in Unit 5 (beam 43C to column 419A)
which contained a 1-1/8" A490 high strength bolt without the required washer, and two joints in Unit 3 (beams 235E to welded clip and 237D to welded clip) in which all bolts did not have plate or bar type washers over the slotted bolt holes as required by procedures and specifications. While not in the specific sample selected for examination, the inspector also noted that Unit 3 structural column 12A had been anchor bolted without the use of washers as required by the design drawing (no. EBASCO G-3435). The failure to execute the inspection program to verify conformance with all bolting requirements is contrary to the requirements of 10 CFR 50, Appendix B, Criterion X.
This is an apparent item of noncompliance (50-508/509/81-02-04).
c.
Review of Quality Records
.
The inspector examined the quality records pertaining to 10 structural
steel connections in Unit 3 reactor auxiliary building and twenty-five connections in the Unit 5 reactor auxiliary building. These connections included the bolting identified in paragraph 3.b above, and included quality control inspection reports (QC-19 formsf and the recent as-built drawing for Unit 5 steel associated with concrete placement 5 ASS-010-362 (perforced January 16,1981). Also requested for review were the records of inspection for anchor bolting of column 12A. The records were examir;ed for completeness, accuracy, and compliance to the requirements of the procedures, codes, and specifications identified in paragraph 3.a. above. A comparison of the inspection record for five of the Unit 5 joints with the actual installation revealed a discreoancy in the identified nurrber of installed bolts.
Inspection record no. 5-SB-42 of November 6, 1980 indicated two connections numbered 270F-260A and two connections numbered 270F-262A each contained 8 bolts, whereas the design drawing and actual installation coatoined only 4 bolts per connection.
Similarily, for connection 251F-247E-263C the report indicated there 12.
It was also were 14 bolts in the joint when there were only(QC-19 form) generated determined that there was no inspection report l
for the final. inspection of anchor bolting for column 12A as required by procedure CP-05.
Further, the inspector found that the Unit 5 as-built drawing for structural steel associated with concrete
!
. _ _
__
__.
-.--
-
. - -
.
.
-
-
-
.
.
.
.
placement 5 ABS-010-362 had not been properly completed in that there were no inspector initials or stamps adjacent to each joint shown on the drawing as required by procedure CP-05.
The failure to raintain adequate records of quality activities is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVII.
This is an apparent item of noncompliance (50-508/509/81-02-05).
d.
Contractor and Licensee Actions Based on the findings of the inspection, the contractor issued a self-imposed stop work order for structural steel on January 12, 1981. On January 23, 1981 the licensee issued a letter to the contractor regarding the stop work order indicating that all accessible bolted and welded connections in the Units 3 and 5 reactor auxiliary building will be reinspected, that 20% of bolting would be checked for torque, and that all bolting and welding documentation would be reviewed. As of January 30, 1981 licensee representatives reported that approximately 5% of the bolts checked for torque were found to be insufficiently torqued and that additional instances of icproper bolting and documentation errors were detected.. The effectiveness of the actions taken by the licensee and the centractor will be examined in conjunction with follosup to the items of noncompliance.
4.
Containment Post Weld Heat Treatrent Activities (CBI)
Chuago Bridge & Iron (CBI) activities related to the post weld heat treatt:!nt of the Unit 5 containment vessel construction hatch subasserbly were examined. The examination included: a review of the controlling procedures (CBI No. HT-11 Rev. 9 and instruction no. HT-11, Rev. 2);
examination of the facilities and equipment utilized; periodic observations of actual heat treating operations; and examination of heat treat inprocess records, equipment calibration records, job supervision, and quality control coverage. The activities were examined for compliance to the requirements of the ASME B&PV Code Section III and the PSAR.
The activities were found to be controlled and in accordance with code re.quirements.
No items of nonconpliance or deviations were identified.
5.
Allegations Regarding Improper Dispositioning of Nonconformance Reports On January 22, 1981 the inspector received allegations regarding the improper dispositioning of nonconformance reports. The allegations, as understood by the inspector were as follows:
a.
NCR No.12462 called for reinspection of welds on hangers provided by ITT-Grinnell and referenced an " attached letter". The NCR was closed out ba' sed on an inspection that was accomplished without removing paint from the welds (as required by the welding code)
and there was no letter attached to the NCR.
.-
-.
.
.__ _
.
.
.
.
.
,
-8-b.
NCR No.12477 was issued against nuts which appeared to be defective.
The corrective action included testing a sample of the nuts for adequacy, but traceability was not maintained of the sample nuts.
It cannot be assured that the nuts that were tested were the proper nuts since traceability was lost.
c.
NCR No. 13296 was voided with " funny wording".
The inspector reviewed the corrective actions of these and other NCRs with cognizant licensee and EBASCO representatives. Pertinent documentation associated with the NCRs was also examined. The findings were as follows:
NCR No.12462 - The statement regarding reinspection without removing paint was determined to be correct.
Licensee representatives stated, however, that it was never intended that a fonnal reinspection (i.e. removal of paint, etc.) be performed, and that documentation was available to support this position. The "atta9ed letter" was located, and although it was not physically attached to the NCR it was in the licensee's record system. This item is unresolved pending receipt of this additional documentation regarding reinspection throughpaint(50-508/509/81-02,-06).
NCR No.12477 - The NCR was found to be open.
Licensee representatives stated that the loss of material traceability had been previously recognized and appropriate action'had been
.
taken (i.e. rejection of the NCR response). This item
'
will be examined further following receipt of a response l
which is acceptable to the licensee (50-508/509/81-02-07).
NCR No.13296 - The allegation was not substantiated. The NCR had been voided based on the fact that the stated nonconformance (lack of source inspection) was determined invalid (i.e.
,
source inspection had been performed).
!
In the sample of additional NCRs selected for examination it was found that NCRs had been voided without a clear explanation (e,g. NCR 12208 and 13117), and were voided following correction of the condition (e.g.
NCR 12120) or discarding of the component (NCR 12213).
Licensee management reprasentatives explained that written guidance for voiding NCRs is not sufficiently detailed and that actions would be taken to correct this condition. Management representatives also comitted to a 100%
review of voided NCRs to assure that no adverse conditions had gone uncorrected. This matter is unresolved and will be further examined following completion of licensee actions (50-508/509/81-02-08).
.
I l
!
- - -
_ _ _ - -
-
.
-
._
.
.-
.
.-
.g.
6.
Safety Related Pipe Support and Restraint Systems The licensee has procured a new design of pipe clamps for the project.
The clarrps were designed by ITT-Grinnell and are provided under contract 3240-04. The devices utilize a riveted construction, which is not addressed in the ASME B&PV Code Section III, Subsection NF. Acccrdingly, the inspector requested the design information (and code cases, if applicable)
pertaining to the new clamps, which verify that the design and materials are consistent with code requirements. This item is unresolved and will be examined further upon receipt of the requested information (50-508/509/81-02-09).
7.
Concrete Batch Plant Operations a.
Observations of Work Activities and Facilities /Eauipment The inspector examined the following aspects of Associated Sand and Gravel (AS&G) main and stand 5y concrete batch plant operations:
accuracy of material control, temperature control, control of batch records, inspection, testing, equipment performance, aggregate /
cerrent/ water / admixture storage and handling, moisture control, and mix design adherence. The activities were examined for compliance to the contract specification, ASTM, PSAR, and pertinent contractor procedure requiranents (ASG Inspection Procedure No. 4, ASG Control of Measuring and Test Equipment Procedure No. 6, and ASG Handling, Storage,andShippingProcedereNo.7).
-
The operations observed were found to be satisfactory. No items
,
l of noncompliance or deviations were identified.
b.
Review of Quality Records The quality records associated with batch plant / equipment inspections for the last four months, cement certification, and aggregate quality were examined for compliance with the requirements of the contract specification, ANSI / ASTM and the PSAR.
No items of noncorrpliance or deviations were identified.
8.
Concrete Testing (PTL)
The inspector examined the test results for the past 8 month period of concrete testing performed by PTL for initial set (ASTM C403), modulus and durability (ASTM
-
of elasticity and Poissons ratio (ASTM C469)iance to ASTM, specification,
!
C-666). The results were examined for compl and PSAR requirements. While all the results were found to be satisfactory, it was found that-results for off-site testing appeared to take an excessive amount of time.
For example, durability test results for samples taken in July 1980 had not been received at the site until January 1981.
Licensee rep esentatives agreed to review this situation and take action to expedite off-site testing performed by PTL.
No items of noncompliance or deviations were identified.
.-
.-
.
.. _.
_
_
---
-_
-
-._ _
_.
.
.-
.o
.
,
-10-9.
Unresolved Items Unresolved items ar'e matters about which information is required in
'
order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Three unresolved items were identified during this inspection and are discussed in Paragraphs 2.C, 5 (2 items), and 6.
10. Management Meetings Management meetings were held on January 16 and 29, 1981. Licensee and Ebasco representatives that attended the January 29, 1091 meeting are denoted in paragraph 1.
During the meetings the inspector summarized the scope and findings of the inspection identifying the unresolved items discussed
,
in paragraphs 2. 5 and 6 and the items of noncompliance discussed in paragraphs 2.a. 3.a. 3.b and 3.c.
Licensee representatives stated that action would be initiated on the concerns identified.
.
v