IR 05000508/1987003

Insp Rept 50-508/87-03 on 870512-15.No Violations Noted. Major Areas Inspected:Licensee Actions on Previous Insp Findings Re Util Readiness Review Program Implementation

ML20215G166
Person / Time
Site:	Satsop
Issue date:	06/02/1987
From:	Pate R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20215G129	List: IR 05000508/1987003 ML20215G126
References
50-508-87-03, 50-508-87-3, NUDOCS 8706230146
Download: ML20215G166 (13)

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M U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report,No.' 50-508/87-03

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Docket No.'50-508'

Construction Permit No. CPPR-154 Licensee:

. Washington.Public Power Supply System (WPPSS)-

P.- O. Box 1223 '

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Elma, Washington 98541

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Facility Name:. Washington Nuclear' Project 3 Inspection Conducted:

May 12-15, 1987 Inspectors:

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I!J 9/87 A. D. Toth, Proj ct Inspector.

Date. Signed

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R.' J. Pate, Chfef~

Date Signed Reactor ~ Safety Branch L. R..Abramson, Statistician NRR/Probablisti, Risk Assessment Branch l

Approved by:

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R~. J. Pate, Ct)ief Date S'ignsd

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Reactor Safety Branch Summary:

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Inspection on May 11-15, 1987 (Report No. 50-508/87-03)

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i Areas Inspected:

Special announced inspection by a regionally based I

supervisor and inspector, and an NRC technical staff statistician, of the-licensee actions on previous NRC inspection findings regarding the WPPSS Readiness Review Program implementation. Inspection procedures 30702, 30703, 92701 1an'd'92702 were considered for inspection guidance.

Results:

In the areas inspected,'no violations were identified.

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DETAILS 1.-

Persons Contacted

~ Washington Public Power Supply System

• P. D. Olson, WNP-3 Program' Director

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• D. R.'Coody, WNP-3 Principal Quality Assurance Engineer'~

• L. J. Garvin, Readiness Reviews Program Manager (Construction QA. Manager)

• R. L. Knawa, Construction Assurance Program Manager

• N. F. Blais, WNP-3 Quality Assurance Manager

• D. I. Hulbert, Engineering Manager - WNP-3

• J. L.-Perreault, Engineering

• J. D. Guberski, Plant Technical Manager

• D. W. Coleman, Licensing Manager

• R. B. Glasscock, Director, Licensing and Assurance EBASCO

• R. M. Taylor, WNP-3 Project General Manager

• H. Toturgul, WNP-3 Civil Lead Engineer (ESSE)

B. Bennett, Contract Administration Manager.

• F. Teague, Resident Engineer

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• W. K. Drinkard, Principal QA-Specialist Bechtel Power Corporation

• T. A. McCormick, Construction Assurance Program Team Leader NESCO (WNP-3 Owners Group Agent)

• J. A. Adams, Site' Representative Department of Energy - Bonneville Power Administration (DOE-BPA)-

• D. Smithpeter, Project Representative

• Designates persons in attendance at exit meeting 8:00 - 9:30 A.M.

May 15. 1987.

2.

Project Status The WNP-3 facility is reported as 76% complete, and has been in a deferred plant construction status since mid-1983. Some work activities continued through 1986, to seal buildings, close piping systems, put equipment into long-term lay-up, and clean up construction debris and remove temporary construction materials. Some electrical work continues to complete feeders to power panels and transfer preservation electrical loads from temporary construction power sources to permanent plant power sources. There appear to De no significant construction activities at the plant. A plant tour by the inspectors during this inspection showed that the facility was generally clean and protected from the element.-.

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The licensee advised the inspectors that' currently there are 160 WPPSS/EBASC0/ contractor personnel-assigned to the WNP-3 project, at the site, at the EBASCO New York engineering offices, and in the Richland-corporate offices, including 22 craft at'the site. There are 28 craft and 50 non-manual EBASC0/ contractor personnel.on-site, to be reduced to 28 non-manual and no craft by July 1, 1987;. preservation activities

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would be fully assumed by WPPSS personnel (about 18) on that date.

Further reductions of EBASCO staff are anticipated through 1987/1988.

Engineeringstaff(about60 engineers)inNewYorkEBASCOoffices continue with packaging of design work, which is anticipated to be complete July 1988.

3.

Readiness Review Program Status and Schedules In January 1985 WPPSS submitted a readiness review program proposal to NRC. The first phase of this program was described as encompassing all engineering and construction complete at the time that construction was suspended in mid 1983. Schedules for completion of the various elements of.the reviews were submitted in 1986. During the late part of 1986 and early 1987, WPPSS verbally advised the NRC of various delt * and deferrals; these have not been documented in correspondenct o NRC.

These program changes arose from WPPSS budget reductions ano problems encountered during the reviews. During the current inspection, WPPSS advised the inspectors of the current status of the program; the

inspectors requested that this information be fonnally documented to NRC,

'connensurate with prior program submittals and approvals.

A.

WRRP (General WNP-3 Readiness Review Program)

The general WRRP will be terminated by July 1,1987, with exception

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of the Preservation Program element.

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Preservation Program The Preservation Program will continue as necessary to preserve the

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facility assets for future licensability.

C.

EAP (Engineering Assurance Program)

The EAP will be terminated July 1, 1987. None of the originally planned review modules will be completed by that date, and these will be deferred until future project restart. The Piping / Supports and the Civil / Structural modules had been worked to date, but will not be completed as originally scheduled.

D.

CAP (Construction Assurance Program)

The CAP will be terminated July 1, 1987. The Earthwork module had been submitted to NRC and approved. The Concrete module will be submitted by the end of May 1987. The two QC inspectors who had performed the detailed reviews of concrete records had already been released prior to the current inspection. The WRRP management

advised that the CAP Manager and the Team Leader for the Concrete module were to be released June 26, 1987. The licensee suggested

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.that any NRC site inspection efforts following the submittal of the j

~ Concrete module (about June 1).should be conducted prior to June

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However, records clerks.would be available on-site, in addition -

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to technical and management staff of the WNP-3 project organization,.

to assist the in nectors after the June 26, 1987 date.

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Review of Licensee Actions Regarding Previous Inspection Findings i

Previous NRC inspections and meetings with the licensee identified.

questions and issues regarding licensee's efforts and results of the j

Readiness. Review Program relative to earthwork and concrete construction.

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Licensee's concerns.regarding NRC interpretation of program commitments had also been addressed. During the. current inspection, NRC staff

. interviewed personnelf and examined records relative to the status of

~ licensee actions and concerns in response to the following NRC inspection reports.

A.

Evaluation of Construction Assurance Program Module C3-01, Earthwork (Reference NRC Inspection Report 50-508/86-12)-

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The licensee had investigated the findings of this report, and for

r the following items, identified additional information, approaches i

to address the' findings, and comments regarding the significance to the review program conclusions:

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R (1).(86-12-02, Closed)' Two items mentioned in the FSAR were noted as not having been identified in the' CAP-C3-01 final report.

(Ref. Report 86-12,'SectionsC.3.a.(5),C.3.b,andC.8.b.(1))

The first item involved shotcrete protection of the excavation surfaces. The licensee noted,that this was not a regulatory'

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requirement related commitment, but only construction aid i

information,~and thus was not intended to be discussed in the CAP program. The inspectors examined construction photographs to demonstrate that such excavation protection had in fact been performed. This item is closed.

The second item involved techniques used for obtaining data for mapping construction excavations. The review of mapping is included in the CAP final report FSAR commitment table as item 21. The results of the mapping effort were not separately reviewed by the CAP, since such results were already fully incorporated into an FSAR appendix via copy of the consultar,ts report. The licensee stated that no further review of this subject was planned. This item is closed.

(2)

(86-12-05, closed) A apparent change in the type of sand used b"

in soil-cement mixes appeared to require additional qualification data, and this item did not appear as an attribute to be checked b (Ref. Report 86-12, Sections C.4.a, C.7.a.(1)y the CAP review.,C.7.a.(3),C.7.b.(2).(b)and C.8.b.(2))

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l Thelicenseedemonstratedtha'tdesignmixcontrbl,wasan

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' attribute of the C3-01 checklists CAP-D-C-01-01 and -03.

The source of sand for the soil-cement was changed during the course of construction, with the implication that this resulted in a change of mix design. The. licensee stated that the mix design had not changed; although the sand source had been changed twice. The NRC inspector also noted that the sand source had changed twice and also the design mix designation on the batch plant records had changed accordingly. However, whether the mix design changed or only the sand changed is not i

important to the acceptability of the soil-cement placements.

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Both the licensee and the NRC consultant found the mix to be acceptable, as noted in tLe NRC report 86-12. The licensee (

plans no further review of this subject. This item is closed.

(3) The C3-01 Module did not include an element of as-built reviews, and an observation regarding rock stress consideration-

was noted as possibly relevant to such an approach.

(Ref.

Report 86-12,SectionC.6)

The licensee stated that the subject of rock stresses was not considered in the earthwork module. Rock stress is a more appropriate u bject for the EAP and would be subject of separate correspondence with NRC. As-built reviews were

considered for earthwork via records reviews.of lift maps, compaction records, and other documentation of the work. The inspectors had no further questions on this matter.

(4) Earthwork soil-cement compaction records did not appear to include certain acceptance criteria for QC inspectors at the time of placements, and associated laboratory test records were marked "N/A", rather include the laboratory test number.

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I Report 86-12,SectionC.7.b.(2)(b))

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Licensee's research into this matter clarified that the compaction records utilized the on-site test laboratory forms for recording field data; this form had a space for entering the laboratory test record number which contained the acceptance data / criteria for field inspection. However, much of the laboratory work was conducted by an off-site laboratory that provided test results to the site engineer (EBASCO), who transmitted these to the testing contractor (PTL) via letter, who then conveyed the criteria to the QC inspectors. This resulted in the field QC inspectors neither needing, nor knowing a specific number for, the actual laboratory test record; thus they marked the form "N/A". The licensee plans no further review of this subject. The NRC consultent had previously confirmed that existing records indicated that proper mixes were used and evaluated by field personnel. The inspector had no further questions on this matter.

(5) The C3-01 report in three instances indicated that test results I

(density tests, moisture content, and compaction records) were all acceptable. The NRC consultant clarified that some of the

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test results fell outside the target limits, but still within the statistical error band allowed by the specification.

(Ref.

Report 86-12,SectionC.7.a.(3),andC.7.b.(2).(b))

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The. licensee requested. clarification of the consultant's

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concerna The inspector noted the consultants conclusions of acceptability of the data and confirmed that NRC has no

questions on this matter.

(6) The C3-01 report " Methodology" section described a " random i

sampling selection of attributes to be inspected", which did not appear to be a sound philosophy for general application to I

the Construction Assurance Program.

(Ref.. Report 86-12 Section C.6.a.(1))

The licensee noted that this unfortunate. choice of wording did not reflect the concept for CAP reviews, nor the actual a'pproach taken for the Earthwork review, as fully described in

'other sections'of the C3-01 report.

Inspection attributes were selected based ~upon engineering review and judgement; random

. sampling technique was in some areas utilized to select the items to be reviewed using the selected attributes (criteria).

The licensee' plans no further review of this matter. The

. inspector took-note of the licensee's clarification, and had no question regarding the selection of attributes for the Earthwork review.

(7) The C3-01 report " Methodology" section described a stratified random sampling statistical approach for selection of work-to inspected..The NRC questioned the general applicability

'to future CAP modules.

(Ref. Report 86-12,SectionC.6.a.(2))

The licensee. requested clarification of the NRC concern in this area; this is discussed elsewhere'in this report. Due to the i

small scope of earthwork performed, and the extensive records

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reviews performed by the licensee, neither the NRC-consultant

nor inspector had any concern regarding the sampling approach for the Earthwork review. The. subject of statistical sampling was included in the NRC report ~to advise the licensee of the-NRC concern about the use of-statistical sampling in future modules.

B.

Inspection of Construction Assurance Program Module C3-02, Concrete (Reference NRC Inspection Report 50-508/86-13)

The licensee had investigated the findings of this report, and for

'the following items, identified additional information, approaches

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to address the findings, and comments regarding the" significance to the review program' conclusions. The inspector emphasized that

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follow-up items identified in the report 86-13 are not necessarily j

deficiencies, but in most cases involved identification of licensee data development which was not yet complete at the time of the.

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inspection, and which'would be considered by NRC during an

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integrating final review and inspection:

(1) (86-13-01,Open)

plans did not appear'to include SamplinfRef. Report 86-13, Sections 7and12)

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representative samples.

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The licensee reconsidered the sampling plans as executed, and l

concluded that representative 5 samples had been selected. These I

included consideration of the number of concrete placements

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conducted by each contractor, a check to assure that the J

selected samples generally encompassed the period of L

performance of each contractor, determination of and inclusion

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of each principal. concrete structure, determination of and I

inclusion of each principal type work' activity, and other elements. The inspector acknowledged validity of this

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l clarification and reiterated that the question'of representativeness was principally related to' limited documentation to demonstrate review and incorporation of I

information regarding past problem history. The inspector also acknowledged that there was clear evidence that the team leader had reviewed past NRC inspection reports and other problem histories, and either _ incorporated some related inspection

attributes into the review plan,.or had found that they were

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already encompassed by elements of the plan. Topics such as rebar walkdown.and quality control inspector training were such elements. However, an integrated consideration of past NRC inspection findings, audit reports, surveillance reports, and nonconformance report trends for each contractor was not included in the module plan. An integrated consideration of these areas will be considered by NRC during review of the final module C3-02 report.

(2) (86-13-02,-Open) The nature of the proposed review of concrete l

compressive strength tests was not defined.

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86-13,Section8)

The licensee stated that the tests would be performed as

prescribed by the ACI-214 standard identified in the CAP C3-02 review plan, for those 60 concrete placements selected for review of other attributes. The results of the review, and relationship to overall concrete work, will be considered by NRC during review of the final module C3-02 report.

(3)

(81-05-H, 0 )en) Two concrete related construction deficiencies (10CFR50.55ereports)didnotappeartohavegenericaspects addressed.

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The licensee noted that one of the two reports related to steel embed plate welds', and that all steel embed work had been deferred for review under a future CAP module, and was not within the scope of the Concrete module C3-02. The inspector noted that this specific issue will be considered an open item to be addressed when the future module is schmitted, if construction is restarted.

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The licensee further noted that report number 35, relating to concrete voids in an auxiliary building wall, had been fully resolved under the estaolished quality assurance program which was in effect during construction. A records review identified significant past NRC inspection activities associated with that resolution. Adoitionally, the licensee noted that the rebound hammer testing and visual walkdown of in place c.oncrete, by a consultant, was incorporated into the CAP program et least

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partly due to the 50.55e review, as was exposed reicforcing steel walkdown and hammer soundings of concrete patch areas.

The inspector concluded that the CAP review team consideration of past 50.55e reports was appropriate relative to concrete work. The inspector had no further questions on this item; this aspect is closed.

(4)

(86-13-14, Open) The CAP team did not appear to have assessed the implications of audit findings relating to QC inspector training, for contractor number 265, that were uncorrected for an excessive time while work continued.

(Ref. Report 86-13, Section12.c)

The licensee stated that review of QC inspector qualifications, including resume' checks to the extent possible at this date, and the review of training records, were included in the CAP Concrete review activities. Their perception was that the specific audit findings were minimal, and that the audit was elevated to final resolution, with increased surveillance of the contractor during the period in question. This matter will be considered in conjunction with the NRC review of the final report, as discussed in item 1, above.

(5)

(86-13-15,Open) CAP review of surveillance reports did not consider many specifically related to concrete activities of contractors.

(Ref. Report 86-13. Section 12.d)

The licensee acknowledged that the purpose of the review of surveillances was to validate the existence and performance of a project wide surveillance program, and not to identify and compile a data base of concrete related contractor performance problems noted during construction. The licensee subsequently decided to review all 671 surveillance reports for contract 265, including 328 involving concrete. The results of negative findings were evaluated, including the issuance and resolution of problem tracking documents (Quality Finding Reports and Nonconformance Reports). The licensee stated that the problems had been characterized, and supported a contention that quality performance of this contractor was equivalent to the otht:r contractors. The inspector requested the licensee to provide the basis of comparison with the other contractors. The licensee stated that this topic will be further discussed with personnel who performed the review, who were not available before completion of the inspection.

Surveillance reports will be considered in conjunction with the NRC review of the final report, as discussed in item 1, abov,

(6)- (86-13-18, Open) Violation.

Failure to identify appropriate rebar spacing criteria in construction specifications.

(Ref.

Report 86-12,Section13)

After some discussion, it was agreed that the licensee's reply to the Notice of Violation did not clearly define the area of contention. The licensee stated that an amended reply would be submitted to reflect the specific condition under contention.

This matter will be evaluated following review of the amended reply.

(7)

(86-13-19,Open) Follow-up Item. (Reclassified Violation)

Failure to identify and correct nonconforming grout installation.

(Ref. Report 86-12,Section14)

The licensee provided additional information subsequent to the inspection documented in Report 86-13, and explained circumstances of the nonconforming condition in a reply to the Notice of Violation. During the current inspection, the inspector examined the additional data which demonstrated that revised drawings, procedures and computer logs provided identification and control over the nonconforming condition.

The licensee reply appears accurate and an acceptable basis for concluding that a violation of NRC requirements was not involved.

The licensee further advised that review of grouting work has been deferred for inclusion in a future CAP module, and would not be addressed in the C3-02 Concrete module. This subject of generalized grout cracking, observed by the NRC inspector, will be considered an open item pending construction restart, or resumption of the CAP program.

(8)

(86-13-21, Closed) The C3-02 Concrete Module checklist CAP-D-C-O b l5 (Cadweld In Process Tests) did not appear to encompass verification that cadweld crews performed their qualification splices at frequencies required.

(Ref. Report 86-13, Section 15.e)

The licensee clarified that this checklist was directed toward a sampling review of completed splice test data, and does not focus on qualification of the cadweld crews. However, the licensee demonstrated that the as-applied checklist CAP-D-C-02-7 includes data which addresses the qualification testing of each crew. Samples of these checklists have been

examined by the NRC consultant with no negative observations.

The inspector had no further questions on this matter.

(9)

(86-13-23,Open) The CAP-D-02-26 checklist appeared somewhat ambiguous in its expectations of reviewers, relative to class

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II masonry walls.

The licensee clarified that the walls were constructed to quality class "G" requirements, and although some records exist

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regarding their' construction, the usual quality control recor'ds'

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review of'this area will. be deferred, and not included in the

scope of the.C3-02 Concrete module < This item will be:

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considered an open item pending construction' restart, or-H

. resumption of the CAP program.-

(10) The licensee requested clarification of thel"a'reas of~NRC 11nterest" which did not appear to be encompassed by the CAP j

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.(Ref. Report 86-13,Section.11)

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l prioritized.and abbreviated list of concrete review topics.

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• The inspector explained that those_ inspection report items'of.

Section8(Concreteanchorboltsandembedplates)-andSection'

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-9 (Core drilling, Bending.of reinforcing steel,-and. grout j

walkdowns)-were the items of principal interest- (i.e.,

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identified as Follow-up' Items, and labelled with an outstanding'

item number).

C.

WPPSS and NRC Meeting of January 7,1987, Readiness Review Program (Reference NRC Inspection Report 50-508/87-01):

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The licensee had reviewed this. report, and for'the following items,

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identified additional information and provided clarifying comments-regarding the significance to the review program conclusions:

(1)- Attendees listed Mr.' G. Block, Manager. of Engineering Assurance Program (Ref. Report 87-01, Section 1) '

The licensee corrected that Mr. Block was not in atten' dance at the meeting, but rather the WPPSS presentation relating to

Engineering Assurance activities was presented in conjunction with presentations by other attendees.

.l (2) Lack of.WPPSS current engineering resources limits WPPSS y

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' ability to respond to NRC inquiries regarding specific FSAR l

. bases.

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The licensee clarified that the planned intent of.the i

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Construction Assurance Program included the premise that the FSAR was correct, and that reviews would not include exploration of bases of FSAR items. Accordingly, NRC inspector

inquiries in this area would not be addressed by CAP reviewers.

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b The inspector acknowledged the licensee's clarification and stated that NRC inspector inquiries could be responded to by'

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CAP staff or other parts of the WPPSS organization, or logged '

j as open items to be addressed in the future during project restart.

l (3) NRC position that-WRRP reports needed to reflect an overview which identified the extent of the original QA program.

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The licensee clarified their response that the readiness review program was an additional assurance program which focused on the observable. condition of completed work and records, and it-was.not an overview program.

s The. inspector acknowledged the WP,PSS position.

For the C3-02 Concrete Module, NRC will consider the effectiveness of the past quality assurance program through review of NRC.

documentation of past inspection reports and review of _.

licensee's quality assurance records, in conjunction with the l

CAP Module report.

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(4) NRC stated that adequate consideration of past problems was an NRC concern which encompassed the procedures review question, and this concern would be considered during NRC review of WRRP Module reports.

The licensee stated that the WRRP will not include procedures reviews (other than to the extent described in the CAP plan).

The licensee also stated that where problems appeared in the reviews / inspections of end products, the associated procedures-were in those cases reviewed in great detail for that product.-

The inspector acknowledged the licensee's position. The NRC review of the C3-02 Concrete will consider past problem history, including history of procedure problems.

(5) Recent inspection data indicated that the Construction Assurance Program reviews did not include a timely and thorough examination of past problems and contractor performance history to focus sampling plans and review attributes.

The licensee disagreed with this NRC conclusion ;nd summarized the problem reviews performed by the team leader and noted examples of review plan elements related to past problems considered.

The inspector acknowledged the data described by the licensee and described his view of an integrated examination of NRC inspection findings. internal audit reports, surveillance reports, and nonconformance reports as a data base to characterize individual contractor performance. The licensee's j

conduct of such a review is not required by NRC under the

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voluntary WRRP/ CAP program, although the inspector considers

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that it may be implied by the descriptions in the Construction Assurance Program approved by NRC. The absence of CAP implementation of this problem search approach would not be a constraint on NRC consideration of this data base.

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(6) Recent NRC inspection data indicated that the license selection of sample populations and sample size have resulted in sampling

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plans not representative of the various activity populations.

The licensee disagreed with this conclusion.

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The subject of sampling plans was discussed in detail during the current inspection, as discussed in Section 5 of this report, below.

5.

Discussion of Sampling Plans, Encompassing Issues Raised in the Above

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Reports (Ref. Report 86-12, Section C.6.a.(2), Report 86-13, Sections 7, 12,17)

WPPSS management met with the inspection supervisor, inspector, and the NRC statistician to review the samplino procedure and discuss limitations of the sampling aspect of the concrete. review module C3-02:

l A.

Statistical Premise The NRC statistician agreed that although the population of WNP-3 concrete contractors may not be completely homogeneous, a statistical statement can be made about the average of all contractors. A statement about an individual contractor requires an inference about the similarity of the contractors, provided by additional data beyond random sampling of all contractors as a single population; this is the basis for NRC interest in the performance history evaluation of individual contractors.

The NRC statistician agreed that: to the extent that all concrete contractors are similar, and constitute a homogeneous population, statistical conclusions may be made-regarding generic type problems across all contractors.

If the population is not homogeneous, then generic problems across any one contractor can be detected provided the problem is of sufficient extent to raise the deficiency rate average above 5%.

The licensee representatives stated their confidence that no single contractor was significantly different than any other, with regard to quality performance. The inspectors stated that this is a significant aspect for the CAP concrete review documentation to demonstrate.

B.

Statistical Conclusion The statistical conclusion states that if no design significant deficiencies are found in a random sample of 60 items, then with 95%

confidence the work of contractors has an average of 5%, or less, design significant deficiencies. The NRC statistician noted that

"or less" could very)well be zero, but there is no statistical basis (with 95% confidence for concluding that it is anything other than less than 5%.

C.

Statistics as an Element of Additional Assurance l

The licensee noted that the statistical review constitutes only one element of the concrete module review activities; the CAP module review activities are an additional assurance to the existence of quality assurance measures implemented during construction. During the CAP reviews, many aspects involved 100% reviews of key records,

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and reviews of documents which demonstrated that quality assurance was a functioning element of.theiconstruction. process.

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6.

Management Meeting.

At.the conclusion of the inspection a meeting.was held with WPPSS management and staff at the site May 15, 1987.

Personnel in attendance arenoted(*)inParagraph1ofthis: report. The results-of this inspection, as. described herein, were summarized at that meeting.

The licensee representatives requested.a meeting withL Region V on or -

after May 22, 1987 to-present to.NRC reviewers the overview and results of-the Concrete Module C3-02' readiness review.

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