IR 05000508/1982010

IE Insp Rept 50-508/82-10 on 820503-07 & 17-21.No Noncompliance Noted.Major Areas Inspected:Licensee Action on Previous Enforcement & on 10CFR50.55(e) items,post-weld Heat Treatment,Electrical Penetrations & QA Procedures

ML20054G856
Person / Time
Site:	Satsop
Issue date:	06/04/1982
From:	Dodds R, Haist D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20054G842	List: IR 05000508/1982010 ML20054G841
References
50-508-82-10, NUDOCS 8206220358
Download: ML20054G856 (14)

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U. S. IiUCLEAR REGUL\ TORY C0!DiISS103

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.:. REGIO!! V

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Report tio. 50 50R/R2 10 Docket tio. 50-508 License ti CPPR-154 Safeguards croup Licensee: Washinoton Public Power Supply System P. O. Box 1223 Elma. Washington 98541

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Facility tiace: WNP-3 -

Inspection at: WNp-3 Site (Satson)

Inspection conducted: Mav L.7 and 17-21.1982 Inspectors: '///;h *

f/[ g //32 6. P. Haist, eactor Inspector '

' Date Signed Date Signed

-=- Date Signed Approved by: , 4[gt-hp R. T. Dod'ds, Chief, Reactor Projects Section 2 / Iface Signed Reactor Constructiofi Projects Branch

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Summa ry:

Inspection during the period of May 3-7 and 17-21, 1982s Report No. 50-508/

82-10).

Areas Inspected: Routine, unannounced inspection by a regional-based inspector of construction activities including licensee action on previous enforcement, unresolved, and inspector followup items; licensee action on 10 CFR 50.55(e)

reportable deficiencies; postweld heat treatment of a reactor coolant pressure boundary pipe weld; installation of containment electrical penetrations; quality assurance implementing procedures for nondestructive examination of safety-related piping; and stud welding acivities on reactor building structural stee The inspection involved 64 inspection hours onsite and 32 inspection hours in-office by one NRC inspecto Results: No items of noncompliance or deviations were identifie (;q RV Form 219 (2)

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DETAILS

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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: Washington Public Power Supply Systen

+*E. L. Stephens, Quality Assurance Engineer

+*0. E. Trapp, Project Quality Assurance Manager

+*J. A. Puzauskas, Quality Assurance Standards and Performance Supervisor

• R. S. Leddick, Program Director, WNP-3/5

+*J. M. Walker, Senior Quality Assurance Engineer

+ D. J. Lagrou, Plant Systems Engineering Supervisor

+ C. Butros, Mechanical Engineering Ebasco Services, Inc. (Ebasco)

+*J. P. Sluka, Manager of Engineering

+* R. Harris, Project Quality Engineer

+*A. M. Cutrona, Quality Assurance Manager

+*L. A. Bast, Quality Assurance Engineering ~ Supervisor

• M. R. Harris, Project Quality Engineer

+*J. Ruimerman, ESSE Mechanical Lead Discipline Engineer Morrison-Knudsen/ESI/ Lord (Joint Venture)'

J. Sowers, Project Quality Director K. Sowder, Quality Control Supervisor G. Jones, Quality Control Inspector D. Shapira, Quality Control Inspector S. Renner, Construction Engineering J. A. Jones Construction Company T. Jeatran, Lead Quality Verification Inspector G. Wickiffe, Quality Assurance Manager

• Denotes those in attendance at exit interview on May 7, 198 + Denotes those in attendance at exit interview on May 21, 1982.

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, In addition, Mr. R. T. Dadds, Chief, Reactor Projects Section No. 2 attended the exit in' erview held on May 7,198 .

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- 2. _ Site Tour

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The inspector conducted a site tour of Unit 3 on May 3 and 17,1982 to observe completed work, work in progress, and storage and maintenance of safety related equipment.

[ No items of noncompliance or deviations were identifie . Construction Status The licensee considered Unit No. 3 to be 5?. percent complete on May 3,

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4. Licensee Action on Previous Enforcement Itams Closed) Noncompliance (50-508/509/81-08/10) Failure to Specify

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The. inspector had previously identified that the Ebasco Site Support Engineering (ESSE) Group had Iot established measures to assure that approved changes to documents were distributed and use Corrective action taken by the licensee-in response to this noncompliance included establishment of ESSE Instruction No. P-005, " ESSE Instruction for Document and Design Control"', and establishment of the position of ESSE vault clerk. Instruction No. P-005 requires the vault clerk to ensure distribution of the master modification file, review and control drawing transmittals, and forward drawings to lead discipline designers for filing in the reference stick file Instruction No. P-005 also pr'ovides measures to ensure

.that drawing and specification modification documents are posted to the appropriate drawings and that stick files are periodically checked for accurac The inspector examined the status of seven drawings having a combined total of thirty-six modification documents from the ESSE R-15 reference stick file against the master modification file to check the effectiveness of implementation of Instruction P-00 No discrepancies were identified. Based upon the above described licensee actions, this item is considered close L

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a-3-5. Licensee Action on Previous Unresolved and Followup Items (Closed) Unresolved Item (50-508/509/81-02/09) ITT-Grinnell Pipe Support Compliance with ASME Section III, Subsection NF The inspector had previously questioned the use of rivets in the fabrication of ITT-Grinnell Figure 215 pipe hanger stiff clamps and compliance of these components with the provisions of ASME Section III, Appendix XVII, paragraph XVII-2411 which allow structural connections that are welded, bolted, or welded and bolte At the time of the inspector's concern, it was not apparent from the stiff clamp load data sheets which design method had been used. Subsequently, de licensee determined that the load rating method had been used to design the stiff clamp. The provisions of Appendix XVII do not apply when load rating design procedures are used (NF-3260) but apply only when linear elastic analysis procedures are used (NF-3132.3). The provisions of NF-3260 for design by load rating contain no express provisions regarding the types of structural connections allowed. Based upon these ASME code provisions and the design method used, this item is considered close (Closed) Unresolved Item (50-508/509/81-04/01) ITT-Grinnell Clamps-Materials, Design Method, Change Control The inspector had previously questioned the materials and design method used on the ITT-Grinnell pipe hanger stiff clamp following receipt of a series of load capacity data sheets with differing information including two different load capacity data sheets with the same revision number. These items also led the inspector to question the method used to control design change The licensee has determined, through discussions with ITT Gr,nnell

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personnel, that Revision 4 of the stiff clamp load capacity data sheet contains the correct material designation and design procedure used. Earlier load capacity data sheets contained erroneous information, some of which was provided by circumventing design and document control procedures during ITT Grinnell's attempts to expedite information to the licensee. The licensee has provided certified material test reports in their final 50.55(e) submittal which confirm the materials used. IIT Grinnell has reviewed and revised their document and design control procedures to ensure that documents accurately reflect design and materials in the future. The inspector reviewed the revised procedures which should preclude recurrence if followed. Based upor, the above, this item is considered closed.

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c. (Closed) Unresolved Item (50-508/509/81-04/02) ITT-Grinnell Clamps-i Effect of Heat Treatment on Rivets

The inspector had previously expressed concern over a reported change in heat treatment procedures for the stiff clamp band ; It was reported that originally, the strap was bent, heat treated, then riveted, but that the procedure was changed to reflect strap bending and riveting followed by heat treatment.

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The licensee has determined through discussions with ITT-Grinnell thatstSapshavealwaysbeenbentandrivetedpriortoagehardening ,

, at 1075 The licensee has determined that load rating tests  !

l were performed af ter this heat treatment cycle in all case Based upon this information, this . item is considered close : d. (Closed) Followup Item (50-508/509/81-08/11-ESSE Document Control System

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The inspector had previously determined that ESSE was not included on the controlled document distribution list for modification documents such as FCR's, DCN's and CWR's but had been receiving them from document control as a matter of courtesy.

The inspector verified on this inspection that transmittal and receipt of interim and final design change notifications (DCN)

is controlled by ESSE Instruction No. P-005. Field Change Requests (FCR's) and Contract Waiver Requests (CWR's) have been replaced by project change proposals which are also transmitted to ESSE and controlled in accordance with ESSE Instruction No. P-00 This item is considered closed, j e. (Closed) Followup Item (50-508/509/81-08/12)-Interim As-Built I of Drawings to Minimize Changes Applicable The inspector had previously determined that criteria established for interim as-builting of drawings and specifications was not firmly established or implemente The inspector, on this inspection, examined ESSE Instruction l No. P002, Rev. I which governs interim as-builting of document This procedure requires that major changes by DCN or FCR be incorporated

, within the original drawing or specification within 15 days after change notice approval. Minor changes by DCN or FCR must be incorporated in the original document within one year or an accumulation of ten changes. The criteria for incorporation of minor changes may be modified by factors such as the rate of construction activity i'

on the contract or significance of the change. This appears to the inspector to be a reasonable approach to interim as-builting but the subjective criteria leave room for abuse. The inspector examined the number of changes and age of changes applicable to the seven drawings discussed in paragraph 4(a) above. Interim as-builting had beer accomplished or scheduled in accordance with ESSE Instruction P-00 i

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-5-In addition, a computer printout (Master Modification File-3)

of drawings which meet the criteria for interim as-builting has been developed and is now in use to identify and schedule drawings for revision. The inspector will continue to monitor interim as-builting practices during routine inspections. This item is considered close (Closed) Followup Item (50-508/509/81-08/28)-Failure of Ebasco Home Office to Provide Results of Site Reviews to ESS The inspector had previously determined that the Ebasco New York Home Office had not provided the results of management reviews of ESSE to the site management for possible actio The inspector, on this inspection, examined management reviews performed in May, 1981 and April, 1982 and determined that copies of these reviews are being furnished to site management for information and action. This item is considered close (Closed) Followup Item (50-508/509/81-08/09)-Site Management Reviews of ESSE The inspector had previously examined the controls established for the ESSE organization to ensure conformance with selected portions of the Company Procedures Manual and had found a number of discrepancie A subsequent site management review had disclosed other deficiencie The inspector, on this inspection verified the correction of these discrepancies, most of which had been resolved by issuance of a site specific procedure No. C6-4, " Applicability of Company and Project Procedures to WNP-3/5 Project." The inspector also examined delegation of authority letters and open engineering items lists for conformance to company procedures as modified by Procedure C6-4 The inspector concluded that these items had been adequately addressed. This item is considered close . Licensee Action on 10 CFR 50.55(e) Construction Deficiencies P_ipe Hanger Stiff Clamps Review of the licensee's final 50.55(e) construction deficiency report had resulted in several followup items for licensee resolution and general concern by the inspector of the ability of the Figure 215 stiff clamp to function effectively for the 40 year design life of the plan (See IE Report 50-508/82-01.)

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s-6-The inspector had identified that heat treatment gtrip charts indicatedagehardeningofstrapmaterialat10g0Fwhgreasthe H1075 condition requires heat treatment at 1075 F + 15 F. The licensee produced evidence that this heat treatment was applicable to a load of 30 straps and was identified by ITT-Grinnell and considered a nonconforming condition. The nonconforming straps were returned to the heat treatment contractor for reheat treatmen Mechanicaltestswereperformedfollowingthereheatgreatment to ensure no loss of mechanical properties. The 1050 F heat treatment strip chart was erroneously supplied to the licensee and included in the 50.55(e) r gor The licensee had agreed to provide code case requests to enable the inspector to compare the actual materials and heat treatments used with those requested for code case approval. The ASTM-A693 Gr630 strap material in the H1075 condition and the A453 Gr660,gypeAorBrivetmaterialfollowedbysolutionheagtreatment at 1650 F for 30 minutes and oil quenched and aged at 1325 F for h to 1\ hours and air cooled is now included in a proposed code case no. N-249-2. The proposed code case accurately reflects the materials used in the stiff clarr The inspector had questioned ITT-Grinnell's practice of beginning with ASME material and recertifying the material as a result of the manufacturing processes or procedures as long as the chemical and mechanical properties are retained following manufacturin The licensee has indicated that ITT-Gr innell was an authorized material manufacturer at the time of fabrication of the stiff clamps. As a material manufacturer ITT-Grinnell may perform or supervise one or more operations which affect the material properties required by the material specificatio Resolution of the above items results in two remaining open items concerning the ITT-Grinnell stiff clamps: (1) NRC acceptance of code case N-249-2; and (2) NRC Office of Nuclear Reactor Regulation (NRR) review of the stiff clamp design, b. Defects Associated with the Shutdown Cooling Heat Exchangers (Closed) Followup Item 50-508/509/80-04/05 On May 22, 1980 the licensee notified the NRC that cracking had been identified in the stainless steel overlay in two shutdown heat exchangers supplied by Combustion Engineering and manufactured by Ametek Corporation. Subsequent written reports also described chloride contamination of the units, below minimum design weld overlay thickness, and tube weld seam crevices and gallin _ _ _ _ ._

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Water contamination of the WNP-3 heat exchangers was discovered in August, 1979 after removal of the nitrogen purge. The stagnan water was found to contain a high concentration of chlorides and an unidentified " crud" was collected from the I.D. tube ' surfaces of both WNP-3 and WNP-5. units. Additional inspections disclosed

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insufficient cladding thickness and cracking of the~ stainless steel overlay on the WNP-3 heat exchanger flange faces. Eddy ~.

current examination of the WNP-3 heat exchangers disclosed indications of tube pitting, 0.D. imperfections, tube dents and distorted tube support signal Several tubes were removed from the heat exchangers and it was determined from visual, metallographic, and bend testing that the WNP-3 heat exchanger tubes were galled and exhibited a lack of fusion condition at the tube seams. As a result all Unit 3 tubes were rejected and replaced. Unit 5 tubes were procured from a different supplier and exhibited shallow longitudinal scratches and some tungsten inclusions which were determined not to be detrimental. The Unit 5 tubes were cleaned to remove chlorides and U-bend specimens were cut and tested for crack susceptibility. The Unit 5 tubes were subsequently determined to be acceptable for use.

l The Unit 3 stainless steel overlay which exhibited cracking was applied using a submerged arc welding process using a single bare wire plus a supplementary powder filler material to increase deposition rates. The overlay was produced in one layer and had a 308L chemistry. Boat samples were taken of the cladding and metallurgical investigations were conducted. Cracking was determined to have been caused by the process used which produced crack sensitive metallurgical phases at the overlay-base metal

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interface due to dilution of the overlay with the carbon steel

, base metal. The dilution factor was also amplified by the use

of a single layer technique in conjunction with the supplementary

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filler metal which requires higher than normal power to ensure i

formation of the large weld bead and consumption of the powder into the wel Corrective action included removal of the overlay to sound base material and replacement of the overlay by the two layer (309L-308L) strip cladding process used on the Unit 5 heat exchanger Investigation of the defects and the repair work was accompanied by appropriate nondestructive examinations. Examinations and repairs were controlled in accordance with a plan developed by Combustion Engineering with review and approval by Ebasco and the licensee. Appropriate licensee representatives were involved in the examinations and repairs. Receiving inspection procedures or source inspection procedures now require internal examination of compor,ents prior to acceptance. In addition, an inspection was conducted on all Class I equipment following identification of the contamination of the shutdown heat exchangers and nonconformance reports were issued for nonconforming condition . - _ - - . __- ..

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The licensee has determined these deficiencies to be not reportable under the provisions of 10 CFR 50.55(e) due to the nature of the defects and redundancy requirements for the shutdown cooling system. This item is considered close Alteration of Radiographs of Pipe Welds (Closed) F.ollowup Item (50-508/31-17/08)

On December 1,1981 the licensee notified the NRC of malpractice

in the form of mechanically enhanced penetrameter images on radiographs of piping subassemblie submitted by Associated P!blag and Engineering Corporation (AP&E) of Compton, California. The ennancement was detected when an Ebasco film reviewer noticed a difference in the appearance of two penetrameter images on the same radiograp When the reviewer examined the radiograph under reflected light to observe the surface of the film it was found that one penetrameter had the 4T hole darkened with a pencil mark.

} Following this revelation, AP&E and Ebasco personnel proceeded to examine radiographs in their shop and Ebasco personnel examined

, all radiographs of spools fabricated by AP&E Compton and delivered t5 the site. The incidence of radiograph alteration disclosed by these examinations was as follows:

Spools at WNP-3/5 Site No. of Spools No. of Welds No. of Films Found by

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_Spaols at AP&E Compton Facility No. of Spools No. of Welds No. of Films Found By

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10 25 46 Ebasco - Lyndhurst 19 23 37 AP&E - Compton 29 48 83

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Corrective action taken in response to this problem included disaissal by AP&E of the responsible individual, review of radiographs of all spools received from AP&E Compton by Ebasco personnel and re-radiography of welds for which film had been altered or review of duplicate film for acceptance. The Ebasco NDE group reviewed re-radiographed or duplicite films of all 37 spools involved with radiograph enhancement and confirmed that the welds

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were of a.. .eptable quality and did not contain rejectable d efect The condit ion was therefore determined by the licensee to not 3 be a reportable 50.55(e) deficienc *

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_ NRC actions have included examination of altered radiographic film at the WNP-3/5 site (Ref. IE Report 50-508/81-17); independent inspection / investigation of AP&E Compton by the Region IV vendor inspection branch (Ref. VIB Inspection Report No. 99900070/81-01);

and issuance of IE Bulletin No. 82-01 on March 31, 1982. This issue is considered closed for the WNP-3/5 facility based upon the above described licensee action . Reactor Coolant Loop Piping - Weld Heat Treatment - Contract 224 The inspector examined the following quality assurance implementing procedures and specifications against the requirements of the ASME B&PV Code Section III:

l Procedure N Title FWP-402N Rev. 0-EC Field Welding Procedure for Thermocouple Attachment FWP-400N Rev. 4 Post Weld Heat Treatment 3240-884WA, Rev. 4 Ebasco Specification - Supplementary Requirements for Welding of Nuclear Pre ssure Components No items of noncompliance or deviations were identifie The inspector examined thermocouple placement on the inside and outside diameter of reactor coolant loop spool no. 741-201 for postweld heat treatment of field weld no. 111. Installation of thermocouples was performed in accordance with the above procedures. The inspector observed various aspects of the postweld heat treatment of field weld no. 111 including location of thermocouples and heater elements, insulation of heat treatment areas, calibration status and certificate of calibration fortemperaturerecorder,certificateofconformanceofthermocouple materials; and cooldown from " soak" temperature to 800 F. The inspector examined the completed time / temperature recording for operation of all thermocouples, g proper temp &ature rise and cooling rates above 800 F; adequate time at " soak" temperature and proper " soak" temperatur No items of noncompliance or deviations were identifie . Containment Electrical Penetrations - Contract 224 Review of Quality Assurance Implementing Procedures The inspector reviewed the following procedures and specifications which govern the care, maintenance, installation and testing of containment electrical penetrations. The procedures were reviewed against the requirements of the PSAR, applicable industry standards and regulatory guide '

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-10-Procedure N Title Specification No. 3240-224 Reactor Building Mechanical Equipment &

Piping Installation Specification No. 3240-55 Electrical Penetrations CMI-010, Rev. 1 Care and Maintenance Instruction - Electrical Penetrations FCP-1053, Rev. 2 Electrical Penetration Installetion FQI-10.23, Rev. 1 Inspection of Electrical Penetration Installation Westinghc.use - Installation and Maintenance Instructions for Electrical Penetrations The inspector noted that the pre-installation and receipt inspection leak tests are not specified in the Ebasco receiving inspection or contractor installation procedures. Leak tests are only conducted upon identificathn of significant leakage as evidenced by inability to maintain nitrogen pressure in the penetration above the minimum of 10 psig during storage. The Westinghouse installation manual is ambiguous on the need for pre-installation testing but the intent appears to be to identify a leaking penetration and repair it before installation. Eba~.co personnel stated that Westinghouse personnel have been consulted and concur with Ebasco's and the contractor's interpretation of pre-installation testing requirement The contractor's installation procedure and inspection procedure does require leak testing in accordance with IEEi-317-1976 requirements following installatio No items of noncompliance or deviations were identified, b. Observation of Work and Work Activities The inspector observed installaHon activities on 12-inch diameter low voltage electrical penetration nos. 110 and 112 and storage and maintenance conditions on various other electrical penetration The inspector observed completed field weld no. 1 and protection and maintenance on the inboard, outboard and annulus portions of electrical penetration no. 112. The inspector observed weld preparations, alignment, fitup and tack welding of field weld no. 1 on penetration no. 110. Other attributes inspected were protection of electrical cables during welding, and protection

! and maintenance on the inboard, outboard and annulus portions of this electrical penetration.

l l Installation activities on both of the above penetrations were j examined against the Westinghouse assembly drawings and applicable

process control sheets (travelers).

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The inspector examined storage conditionsand nitrogen pressures on electrical penetration nos 150 SA, 157 NA, 167fNB'and 148 SA in the Ebasco warehous No items of noncompliance or deviations were identifie Review of Records The inspector examined Ebasco receiving inspection plans and

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records for the four electrical penetrations described in paragraph 8b. The inspector found that receiving inspection plan no. 55 did not include inspection of the inert gas blanket on these electrical penetrations. Although the nitrogen purge is used to monitor penetration module leakage across "0" ring seals and not as a preservative, the Westinghouse maintentnce manual requires that the purge be checked upon receipt and thereafter monitore Maintenance records for these penetrations indicated receipt on January 21, 1981 with maintenance inspections of nitrogen blanket on March 3 and April 21, 1982. It appears that the lack of documentation for receipt inspection was detected and corrected through nonconformance report no. 13914 which was initiated on February 26, 1982. Care and maintenance inspections have been completed on schedule subsequent to this nonconformance repor Based upon the requirement for post installation leak testing and the required monitoring of penetration nitrogen pressures following installation to establish the leakage characteristics of each penetration, the absence of receipt inspection documentation is not considered significant. Ebasco personnel later stated that temperatures and pressures had been recorded upon receipt but had not been included in the documentation package. The receiving inspection plan is being revised to include a check of nitrogen purge pressure No items of noncompliance or deviations were identifie . Safety Related Piping - NDE Aspects - Contract 251-Review of Quality Assurance Implementing Procedures The inspector reviewed the following portions of the quality assurance plan and procedures being used by the nondestructive examination subcontractor to the 251 contract. The procedures were revie'wed against the requirements of the PSAR, contract specification no. 3240-251, Ebasco specification no. 3240-536, 10 CFR 50, Appendix B, the ASME B&PV Code, and ASNT-TC-1 _ - . - _ _ , . . . - , - -.m--_. _

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-12-Procedure N Title Organization Qualification and Certification of Nondestructive Examination Personnel Document Control Procurement Control Receipt of Material Handling, Storage and Shipping Inspection Nonconformances and Corrective Actions Calibration Procedure for Project Measuring and Test Equipment 20. Radiographic Examination of Welds 21. Magnetic Particle Examination - Dry Method 21. Magnetic Particle Ex amination - Dry Particle Yoke Method 22. Ultrasonic Examination of Welds 23. Liquid Penetrant Examination - Visible Dye 23. Liquid Penetrant Examination - Fluorescent Dye No items of noncompliance or deviations were identifie . Containment Steel Structures and Supports - Contract 265-Observation of Welding Activities Within Containment The inspector. examined completed stud welds on beam nos. 404 A-A, 404 A-8, 404 B-A and 404 A-B at the 395' elevation for conformance to the requirements of AWS D1.1 and contractor procedure no. WE-SP-107, Rev. 5. Studs which had been marked by the qu ality verification inspector appeared to be acceptable. The inspector questioned the method of inspection for stud welds and found that the inspectors were inspecting stud welds and initiating inspection reports on a daily basis and marking acceptable stud welds rather than waiting for completion of all stud welds on a structural member and then inspecting the member as a unit as required by procedure no. WE-SP-107. The practice being implemented did not appear to result in any loss of control of inspection status and the contractor stated that the procedure would be revised to conform to the field practic The inspector also observed setup, completed daily process and stud weld operator qualification tests, and in process stud welding on various structural members at the 395' elevatio No items of noncompliance or deviations were identifie _ _ _ - _ - _ _ _ _ _ _ _

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-13-11. Management Meeting The inspector met with the licensee and management personnel denoted in paragraph 1 at the conclusion of the inspections on May 7 and 21, 1982. The inspector discussed the scope and findings of the inspection The findings were acknowledged by the licensee.

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