IR 05000508/1982012

IE Insp Rept 50-508/82-12 on 820607-11.Noncompliance Noted: Failure to Perform Surface Exam of Containment Electrical Penetration Welds

ML20055A064
Person / Time
Site:	Satsop
Issue date:	06/25/1982
From:	Dodds R, Haist D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20055A050	List: IR 05000508/1982012 ML20055A049 ML20055A055
References
50-508-82-12, NUDOCS 8207150442
Download: ML20055A064 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-508/82-12 Docket No. 50-508 License No. CPPR-154 Saf guards Group Licensee: Washinoton Public Power Suoply System P. O. Box 1223 Elma, Washington Facility Name: WNP-3 Inspection at: WNP-3 Site (SATS0P) Insoection conducted: June 7-11, 1982 Approved by: [3d i D. P. Haist, Reactor Inspector 6[2 f/#7_ -

     /Datd Signed Approved by: ([

R. T. Dodds, Chief, Reactor Projects Section 2

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     /Dat6 Signed Reactor Construction Projects Branch Sunnary:

Inspection during the period of June 7-11, 1982 (Report No. 50-508/82-12) Areas Inspected: Routine, unannounced inspection by a regional-based inspector of construction activities including licensee surveillance activities and installation of containment electrical penetration The inspection involved 32 inspection hours onsite by one NRC inspecto Results: One item of noncompliance was identified. (Failure to perform surface examination of containment electrical penetration welds - See details, paragraph 4).

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DETAILS , Persons Contacted 4 The inspector interviewed various engineering, management, inspection, ! and construction personnel of the organizations listed below. Key

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personnel, including those who attended the exit interview are specifically identified below: l Washington Public Power Supply System

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

  *E. L. Stephens, Quality Assurance Engineer

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  *0. E. Trapp, Project Quality Assurance Manager
  *J. A. Puzauskas, Quality Assurance Standards and Performance Supervisor
  *J. M. Walker, Senior Quality Assurance Engineer D. J. Lagrou, Plant Systems Engineering Supervisor

C. Butros, Mechanical Engineering l

C. Tewksbury, Quality Assurance Surveillance Supervisor

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T. Beers, Quality Assurance Engineer Ebasco Services, Inc. (Ebasco)

  *J. P. Sluka, Manager of Engineering

, M. R. Harris, Project Quality Engineer

  *A. M. Cutrona, Quality Assurance Manager L. A. Bast, Quality Assurance Engineering Supervisor
  *J. F. Killian, ESSE Project Engineer
  *T. E. Cottreu, Senior Resident Engineer Morrison-Knudsen/ESI/ Lord (Joint Venture)

l *J. Sowers, Quality Assurance Director W. Holcombe, Project Quality Assurance Manager K. Sowder, Quality Control Manager )j A. Wolcutt, Quality Assurance Engineering Supervisor 1 J. Stone, Nondestructive Examination Supervisor i . * Designates those attending exit interview on June ll,198 . Construction Status ! The licensee considers WNP-3 to be 54 percent complete as of June 1, 198 * Site Tour i ' The inspector conducted a tour of Unit 3 on June 7, 1982 to observe

completed work, work in progress, and storage and maintenance of

safety related equipmen Noitemsofnoncomplianceordeviationsiiereidentifie ; f _ . _ . - ~__, _ _ _ . . - - . . - . . - - - - ~ . _ _ . _ .

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   -2- Containment Electrical Penetrations - Contract 224
^ Review of Quility Assurance Implementing Procedures The inspector examined the following additional procedures which
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govern the installation and testing of containment electrical penetrations. The procedures were reviewed against the requirements of the ASME B&PV Code Section IX and Section III, Subsection NE, the PSAR, and 10 CFR 50, Appendix Procedure N Title FEP-1024, Revision 1 Traveler Preparation and Processing FQP-10.32, Revision 1 Control of Welding WPS-Pl-103-1, Revision 1 Welding Procedure Specification for Welding Carbon Stee No items of noncompliance or deviations were identifie Observation of Work and Work Activities The inspector observed installation activities on 12-inch diameter low voltage electrical penetrations. Observations included the quality of completed containment pressure boundary welds on i penetration Nos.153NA and 149, maintenance and storage conditions on various in process and completed electrical penetrations, and construction continuity checks and insulation resistance test The inspector questioned the absence of quality control coverage ) ' or a status log of electrical tests since Procedure No. FOI 10.23,

" Inspection of Electrical Penetration Installation" requires quality control verification of electrical tests. The electrical quality control supervisor stated that he was aware of the testing and that it is being performed by the construction department for information only and not for final acceptance. The tests will be repeated and verified by quality control personne The inspector observed the calibration block being used for the ultrasonic examination of electrical penetration field welds in the vicinity of the electrical penetrations. The calibration block did not contain any markings to identify it as a calibration block. Contractor representatives, upon questioning, indicated that the block should have been marked and that an identification number had been assigned. Upon further questioning the inspector found that the block had been fabricated on site to an informal, uncontrolled sketch. The block as fabricated appears to meet the

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  -3-basic calibration block requirements of ASME Section V, but
, notches have bt'n added which are not included on the sketc There does not appear to have been any quality assurance or quality control involvement in the procurement of this calibration block for such critical items as block materials, thickness, surface curvature, calibration hole sizes and depths, and block thickness. The contractor quality assurance representatives committed to review the procurement and identification of this block and to institute controls on future calibration block The inspector examined storage and maintenance conditions for installed and partially installed electrical penetrations against the requirements of the applicable care and maintenance instruction and found conditions generally in accordance with that instructio No items of noncompliance or deviations were identifie Review of Quality Assurance Records The inspector reviewed the following quality assurance records associated with low voltage electrical penetration for compliance with the requirements of the purchase specification and installation procedures:
. Weld braze data card for field weld No.1 - Penetration No.10 . Ultrasonic examination report and calibration report for field weld No.1 - Penetration No.10 . Weld braze data card for field weld No.1 - Penetration No.10 . Weld braze data card for field weld No. 1 - Penetration No. 10 . Welder qualification record for welder S-8 (observed welding on Penetration No.110 on previous inspection).

. Welder qualification record for welder S-13 (observed welding on Penetration No. 112 on previous inspection).

. Care and maintenance records for Penetration Nos. 102, 104, 106 and 108 dated May 28, 198 . Qualification and Certification records of Level II (UT) Examiner associated with ultrasonic examinations on electrical Penetration Nos.104 and 10 .

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. Material certification for pressure retraining components on Penetration No. 11 .

Certificate of conformance to seismic requirements of Specification No. 3240-55 and to IEEE 32 . Certification of conformance to requirements of IEEE-31 . Installation travelers for penetration Nos.110 and 11 The inspector noted that Ebasco has not given final approval'to Westinghouse penetration qualification report No. PEN-TR-81-59 but has documented that fact with rionconformance report No. 239-NS ^ s and has informed the field organization that installation may , proceed. A conditional release was not generated as a. result 'f this documentation deficiency. Ebasco committed to examine their conditional release program to ensure that nonconformances' identified by the New York office are reviewed for inclusion in the conditional release progra The inspector noted that confusion apparently exists over the difference between the calibration block identification number and the reference block identification number on ultrasonic examination calibration report Some reports correctly list the calibration block identification number. Other reports have incorrectly listed the reference block identification number for the calibration block number and vice versa. The contractor committed to review completed calibration reports and correct the identification number The inspector questioned the lack of requirements for leak testing the containment pressure boundary field welds on the installation travelers and in the installation and inspection procedure Nos. FCP 1053 and FQI 10.23, respectively. Leak testing is required on these field welds in accordance with the contract specification No. 3240-224 and the ASME B&PU Code, Article NE-6000. Field Construction Procedure No. FCP-1053, paragraph VII.19 states, in part, "It is the intention of this procedure to cover all steps regarding the installation of electrical penetrations...." Field Engineering Procedure No. FEP-1024, " Traveler Preparation and Processing", paragraph VII.B.2 re' quires travelers to be prepared in sufficient detail to control the work activit .

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The penetration seal and electrical continuity and resistance tests :

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are specified in the field construction procedure and quality instruction, however, the travelers for penetration Nos.110 and 112 did not include electrical tests and the ASME leak test. The field construction procedure and quality instruction did not include the ASME leak test requirements. It was not apparent that the

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contractor or engineer have considered the need to perform a leak

test of these field welds or that the test can be performed with the

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electrical penetration modules installed. The licensee and engineer will investigate the circumstances behind this onmision. This item . will be examined further on the next inspection and is considered to be unresolved. Unresolved Item (50-508/82-12/01) During the examination of completed weld braze data cards for field weld No. 1 on penetration Nos. 104,102 and 106, the inspector noted that surface examinations had not been specified nor performed. The ASME B&PV Code Section III, Subarticle NE-5211.1 provides special

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exception for radiography and requires ultrasonic examination plus liquid penetrant or magnetic particle examination of completed welds when the joint detail does not permit radiography. Weld braze data 1 cards for the above penetrations were completed and sent to the l quality assurance records organization. The failure to ' specify and perform code required surface examinations is considered an apparent item of noncompliance with 10 CFR 50, ! Appendix B, Criterion 10, Insoectio Noncompliance (50-503/82-12/02). License Surveillance Activities The inspector began an examination of licensee and construction - manager audit and surveillance activities in an effort to resolve

outstanding followup items on this subject (reference item no /509/80-14-03, 81-14-05 and 81-14-06). The licensee's surveillance activities were examined on this inspectio Licensee audit and construc-tion manager audit and surveillance activities will be examined during future inspection The licensee surveillance program is designed to provide the licensee f with an overview of the effectiveness of contractor and construction i manager quality assurance programs. The program consists of: (1) routine surveillances of portions of contractor and construction manager work activities and (2) in-depth surveillances of critical work activities to assure effective functioning of the applicable contractors quality program during the work activit _ l f

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  -6-The inspector compared the subject and scope of surveillances conducted during the first half of 1982. Critical safety related work activities during that time period have included: (1) reactor building structural steel erection, welding, and bolting; (2) reactor building concrete structures; (3) containment electrical and mechanical penetrations; (4) reactor coolant pressure boundary piping erection, welding and nondestructive examination; (5) safety related equipment satting; (6) containment spray piping erection and welding; (7) auxiliary building piping erection, welding, and nondestructure examination; (8) pipe hanger installation and welding; (9) erection of safety related tanks and installation of containment personnel and escape hatches; (10) electrical equipment setting and installation of electrical cable raceways; and (11) HVAC duct work and hanger installatio Approximately 62 surveillances have been conducted during this time period. In-depth surveillances of work activities have been conducted on electrical containment penetration installation, reactor coolant pressure boundary pipe welding and post weld heat treatment, mechanical containment penetration installation, and airbore radioactive removal unit installation. The in-depth.surveillances that have been conducted appear to meet the philosophy of the governing Ouality Assurance Instruction No. QAI-10-2, although there was no evidence that written checklists were utilized. The surveillance reports for the above described in-depth surveillances indicate that the applicable requirements were researched and examination was of sufficient depth to evaluate the work contractor and construction manager's quality assurance programs. Findings from in-depth surveillances and routine surveillances appeared to have been given appropriate management attention, including corrective action, with the possible exception of surveillances of care and maintenance and housekeepin Of the 62 surveillances conducted, approximately 23 involved care and maintenance and approximately 5 involved housekeeping. These 28 surveillances resulted in 24 findings that tend to indicate to the inspector that equipment care and maintenance and housekeeping are areas where corrective action has been inadequate and management attention is require Critical work activities for which in-depth licensee surveillances have not been performed include reactor building structural steel erection, bolting and welding; reactor building structural concrete; electrical equipment setting and cable race way and support installation; and safety related pipe hanger installation and pipe weld nondestructive examinatio The inspector expressed concern that sufficient resources were not being apolied to provide the licensee assurance that contractor quality assurance I

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i and, particalarly, construction manager surveillance programs were effectively controlling and monitoring work activities. The inspector also expressed concern that the above described repetitious findings in the area of care and maintenance and housekeeping may be diverting resources from j surveillance of critical work activities. The licensee committed to j evaluate the observations of the inspector and take appropriate actio Licensee surveillance activities will be examined during subsequent inspections.

! Unresolved Items ' Unresolved items are matters about which more information is required i l to ascertain whether they are acceptable items, items of noncompliance

or deviations. An unresolved item identified during the inspection is . l discussed in paragraph ,

           . Management Meeting i

! I The inspector met with the licensee and management personnel denoted i in paragraph 1 at the conclusion of the inspector on June 11, 1982.

- - '. The inspector discussed the scope and findings of the inspection and - expressed concern to the licensee over the failure of the Authorized l Nuclear Inspector to detect the item of noncompliance discussed in paragraph 4(c) during his review of weld braze data cards. The licensee

acknowledged this concer .

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