ML17272A850
| ML17272A850 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/05/1980 |
| From: | Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| GO1-80-55, NUDOCS 8003120517 | |
| Download: ML17272A850 (43) | |
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,C g,vs Washington Public Power Supply System A JOINT OPERATING AGENCY v~~~
Ql I iv P. 0, BOX 908 3000 QSO. WASHINCSON WAY RICHLANO, WASHINOSON 99352 PHONS (509) 375 5000 March 5, 1980 G. S. Spencer, Chief Gol-80-55 Reactor Construction and Engineering Support Branch Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596
Subject:
WPPSS NUCLEAR PROJECT NO. 2 DOCKET NO. 50-397, CPPR-93 NRC INSPECTION - HAY 17, MAY 29- JUNE 1, JUNE 11-14, SEPTEMBER 10-14, 1979 REPORT NO. 50-397/79-10
Reference:
Letter G. S. Spencer to N. 0. Strand, dated January 21, 1980
Dear Hr. Spencer:
This letter is in response to your letter of January 21, 1980 (referenced above)'which documented the results of the NRC Inspections conducted on Hay 17, May 29 - June 1, June 11 - 14 and September 10 - 14, 1979, of the activities authorized by NRC Construction Permit No. CPPR-93. The referenced letter identified four (4) items of noncompliance.
The specific NRC findings, as stated in your letter of January 21, 1980, and the Supply Systems response are provided in the appendix to this letter.
I If you have any questions or desire further information, please advise.
Very truly yours, D. L. RENBERGER Assistant Director Generation and Technology DLR/RPS/im
Attachment:
as stated cc w/att: JM Blas - B&R, NY HR Canter - B&R, NY JR Lewis, BPA, Richland V. Stello - Office of Inspection & Enforcement, l DC JJ Verderber - B&R, NY buPS-WIIOSr~ o~I 7
APPENDIX A Washington Public Power Supply System P. 0. Box 968 Richland, Washington 99352 Docket Number 50-397 Construction Permit Number CPPR-93 Notice of Violation Based on the results of NRC inspections conducted between May 16 and September 14, 1979, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC facility license No. CPPR-3 as indicated below.
A. 10CFR50, Appendix B, Criterion IX, states, in part, that "measures shall be established to assure that special processes, including ...
heat treating .... are controlled and accomplished by ... using qualified procedures ...."
Paragraph D. 2. 5. 9 of the WPPSS guality Assurance Program documented in the PSAR states, in part, that "measures shall be established:.. to assure that special processes, including ... heat treating ... are accomplished ... using qualified .... procedures...." .
Contrary to the above, on Hay 31, 1979, it was found that the piping post weld heat treating procedure No. PlJHT-1, revision 4 (entitled "Post Weld Heat Treat Procedure No. 1:) was implemented using a unique method of heat application without the benefit of qualification. The method employed electric resistance heater blankets placed along each side of the weld (approximately 14 inches from the weld center line) rather than directly over the weld. This procedure had been used to heat treat safety related pipe welds including welds 6, 7 and 8 of Burns & Roe isometric drawing No. RFW-419-4.
This is an infraction.
ACTION TO CORRECT DEFICIENCY The Supply System has complied with the intent of 10CFR50, Appendix B, Criterion IX, which states, in part, that "measures shall be established to assure that special processes, including .... heat treatment .... are controlled and accomplished .... using qualified procedures ...." All ASHE welding procedures which require PIJHT are qualified with PlJHT as an integral part of the qualification process. Placing the strip heaters 1', inches away from the center of the weld is not considered unique and requiring special qualification.
Page 1 of 4
0 Based upon an evaluation of the PWHT strip charts for the welds in question, it can be shown that all the requirements of ASNE heating cooling III, rates, Section time NB4620, Post Weld Heat Treatment, (e.g. and at temperature) were complied with, the single exception being that the heating rate (220o F/hr.) for RFW-419-4 weld 6, was exceeded by 50 F during the first hour. The maximum weld temperature attained for the weld was 1150o F which occurred durin~ hold time at temperature.
The ~T during the soak time was 50 F. The temperature directly under the heating coil would parallel the strip charts which showed no indication of any excessive temperature gradients. Since the heating coils were only 1~ inches from the center of the weld there is no reason to assume that the base material attained a temperature approaching the critical temperature of the material. This was substantiated by Report NO. IE-119, Hardness Testing and Metallurgical Examination on Feedwater Pipe Welds at Washington Nuclear Project No. 2, which stated "The maximum temperature reached at any point estimated to be in the range of 1270o F-1310o F."
B. 10CFR50, Appendix B, Criterion V, states, in part, that "activities
'affecting quality shall be prescribed by documented instructions....
Paragraph D.2.5.5 of the WPPSS guality Assurance Program documented in the PSAR states, in part, that "activities affecting quality shall be prescribed by documented instructions ..."
Contrary to the above, on Hay 31, 1979, it. was found that no written instructions had been developed for the operation or adjustment of pipe weld heat treating equipment designed and built for use on safety related piping systems, including welds 1A, 2 and 3 of Burns & Roe isometric drawing RFW-419-5.7.
This is an infraction.
f Action To Correct Deficienc On 8/6/79, Wright Schuchart Harbor/Boecon/General Energy Resources, Inc., (WBG) terminated their contract (2808-215-113) with Seattle Industrial and assumed direct responsibility for the PWHT operations.
Action To Prevent Recurrence WBG has revised the PWHT procedure, purchased heat treating equipment from Cooperheat and developed and implemented a training program for the operators and inspectors. A packet containing the operating instructions and PWHT procedure are attached to the control panel of the equipment.
Page 2 of 4
Date Of Full Com liance Effective 9/12/79 MBG has been performing the PMHT operations. The PMHT has been witnessed by WBG guality Control Inspectors and verified by a guality Engineer to assure compliance to the revised PMHT procedure, PWHT No. 1, Revision No. 9.
C. 10CFR50, Appendix B, Criterion XVII, states, in part, that "sufficient records shall be maintained to furnish evidence of activites affecting quality ...."
Paragraph 0.2.5 of the WPPSS guality Assurance Program documented in the PSAR states, in part, that "sufficient records will be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality..."
Contrary to the above, on May 31, 1979, it was found that sufficient records had not been obtained to furnish evidence of satisfactory heat treating of safety related pipe welding. For example, several heat treat record charts were illegible (e.g. welds 6, 7 and 8 of Burns 5 Roe isometric drawing No. RFW-419-4), thermocouple indications were not recorded on some portions of the recorder charts (e.g. welds 1A and 2 of Burns & Roe. isometric drawing RFW-419-5.7), no operator names had been recorded on neat treating data records (e.g. welds 6, 7 and 8 of Burns 5 Roe isometric drawing No. RFM-419-4, Welds, 1A, 2 and 3 of isometric drawing No. RFM-419-5.7) different and conflicting thermocouple Nos. had been recorded for the heat treatment of the same weld (e.g. the recorder charts and certification sheets for weld 8 of Burns 8 Roe isometric drawing RFM-419-4, weld 1 of isometric FRM-418-7.8, welds 6, 7 and 8 of isometric RFM-418-4), different (and conflicting) dates of heat treatment had been listed on recorder charts and certification sheets (e.g. welds 4, 6, 7 and 8 of Burns 8 Roe isometric RFW-418-4, welds 1, 1A and 2 of isometric FRM-418-5.6).
This is a deficiency.
Action To Correct Deficienc WBG has initiated a program to review all completed PMHT charts and records for the PMHT conducted by Seattle Industrial.. This review activity is overviewed by a guality Engineer who evaluates the findings.
Inspection Reports ( IR's) are initiated as necessary to obtain resolution of the discrepancies found.
Action To Prevent Recurrence As noted in B above, WBG has assumed direct responsibility for the PMHT operation and has initiated a program to assure compliance to the revised PWHT procedure.
Page 3 of 4
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Date Of Full Com l i ance The review of all records initiated by Seattle Industrial and the initiation of IR's for discrepant conditions is estimated to be complete by 4/1/80.
D. 10CFR50, Appendix B, Criterion V, states, in part, that "Activities affecting quality .... shall be accomplished i'n accordance with ...
instructions, procedures and drawings..."
Paragraph 3.2.5 of the WPPSS guality Assurance Program documented in the PSAR states, in part, that "... all project contractors for the nuclear related portions of the plant will be required to have a guality Assurance Program ... the program shall include the following items as ... applicable to the ... construction for which the contractor is responsible." Paragraph D.2.5.5 states, in part, that "activity affecting quality... shall be accomplished in accordance with ... procedures."
Contract 215 Procedures No. PWHT-1 Revision 4,(entitled "Post Weld Heat Treat Procedure No. 1), specifies that heating and cooling rates above 800o F shall in no case exceed 400o F per hour for ASME Section III requirements.
Contrary to the above, on weld lA of Burns 5 Roe May 31, 1979, it was found that recorder chart isometric drawing No. RFW-419-5.7 and weld 6 and 7 (records are somewhat illegible) of isometric drawing No. RFW-419-4 indicate periods of'ime when the heating and cooling rates exceed 440 F per hour.
This is an infraction.
Action To Correct Deficiencies RFW-419-5.7 Weld lA: The review conducted by WBG (see C above) has concluded that due to an excessive cooling rate (excess of 220o F per hour), the weld will be re-postweld heat treated.
RFW-419-4 Weld No. 6: Additional weld repair of this weld is required, therefore concurrent with the repair it will be re-postweld heat treated.
RFW-419-4 Weld No. 7: Final evaluation of Report IE-119 and the PWHT ata from Seattle In ustrial has not been made.
Action To Prevent Recurrence As noted in B above, WBG has assumed direct responsibility for the PWHT operation and has initiated a program to assure compliance to the revised PWHT procedure.
Date Of Full Com liance 4/1/80.
Page 4 of 4
V REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR;8003120517 DOC ~ DATE: 80/03/05 NOTARIZED: NO DOCKET ¹ FACIL:50 397 WPPSS Nuclear Projects Unit 2r Washington Public Powe 05000397 AUTH, NAME AUTHOR AFFILIATION NBERGKR~D,L','ashington Public Power Supply System
.C IP ~ NAME RECIPIENT AFFILIATION ENCERpG ~ ST Region 5g San Francisco'ffice of the Director
SUBJECT:
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Washington Public Power Supply System A JOINT OPERATING AGENCY P. O. BOX 988 3000 GEO. WA5HINCTON WAY RICHLANO, WASHINCTON 99352 PHONE (509) 375 5000 Harch 5, 1980 G. S. Spencer, Chief '01-80-55 Reactor Construction and Engineering pport Branch Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596
Subject:
WPPSS NUCLEAR PROJECT NO. 2 DOCKET NO. 50-397, CPPR-93 NRC INSPECTION - HAY 17, HAY 29- JUNE 1, JUNE 11-14, SEPTEHBER 10-14, 1979 REPORT NO. 50-397/79-10
Reference:
Letter G. S. Spencer to N. 0. Strand, dated January 21, 1980
Dear Hr. Spencer:
This letter is in response to your letter of January 21, 1980 (referenced above) which documented the results of the NRC Inspections conducted on Hay 17, Hay 29 - June 1, June 11 - 14 and September 10 - 14, 1979, of the activities authorized by HRC Construction Permit No. CPPR-93. The referenced letter identified four (4) items of noncompliance.
The specific NRC findings, as stated in, your letter of January 21, 1980, and the Supply Systems response are provided in the appendix to this letter .
If you have any questions or desire further, information, please advise.
Very truly yours, D. L. RENBERGER Assistant Director Generation and Technology DLR/RPS/im
Attachment:
as stated cc w/att: JH Blas - B&R, NY HR Canter - B&R, NY JR Lewis, BPA, Richland V. Stello - Office of Inspection & Enforcement, WDC JJ Verderber - B&R, NY
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APPENDIX A Washington Public Power Supply System P. 0. Box 968 Richland, Washington 99352 Docket Number 50-397 Construction Permit Number CPPR-93 j
Notice of Violation Based on the results of NRC inspections conducted between May 16 and September 14, 1979, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC facility license No. CPPR-3 as indicated below.
A. 10CFR50, Appendix B, Criterion IX, states, in part, that "measures shall be established to assure that special processes, including ...
heat treating .... are controlled and accomplished by ... using qualified procedures ...."
Paragraph D.2.5.9 of the WPPSS guali ty Assurance Program documented in the PSAR states, in part,'that "measures shall be established... to assure that special processes, including ... heat treating ... are accomplished ... using qualified .... procedures...."
Contrary to the above, on Hay 31, 1979, it was found that the piping post weld heat treating procedure No. PWHT-1, revision 4 (entitled "Post Weld Heat Treat Procedure No. 1:) was implemented using a unique method of heat application without the benefit of qualification. The method employed electric resistance heater blankets placed along each side of the weld (approximately 14 inches from the weld center line) rather than directly over the weld. This procedure had been used to heat treat safety related pipe welds including welds 6, 7 and 8 of Burns & Roe isometric drawing No. RFW-419-4.
This is an infraction.
ACTION TO CORRECT DEFICIENCY The Supply System has complied with the intent of 10CFR50, Appendix B,
.Criterion IX, which states, in part, that "measures shall be established to assure that special processes, including .... heat treatment .... are controlled and accomplished .... using qualified procedures ...." All ASt<E welding procedures which require PWHT are qualified with PWHT as an integral part of the qualification process. Placing the strip heaters 1', inches away from the center of the weld is not considered unique and requiring special qualification.
Page 1 of 4
0 0
Based upon an evaluation of the PWHT strip charts for the welds in question, it can be shown that all the requirements of ASME III, Section NB4620, Post Weld Heat Treatment, (e.g. heating and cooling rates, time at temperature) were complied with, the single exception being that the heating rate (220o F/hr.) for RFW-419-4 weld 6, was exceeded by 50 F during the first hour. The maximum weld temperature attained for the weld was 1150o F which occurred durin~ hold time at temperature.
The xxT 'during the soak time was 50 F. The temperature directly under the heating coil would parallel the strip charts which showed no indication of any excessive temperature gradients..Since the heating coils were only 1', inches from the center of the weld there is no reason to assume that the base material attained a temperature approaching the critical.
'temperature of the material. This was substantiated by Report NO. IE-119, Hardness Testing and Metal,lurgical Examination on Feedwater Pipe Welds at Washington Nuclear Project No. 2, which stated "The maximum temperature reached at any point estimated to be in the range of 1270 F-1310o F."
B. 10CFR50, Appendix B, Criterion V, states, in part, that "activities affecting quality shall be prescribed by documented instructions....
Paragraph D.2.5.5 of the WPPSS guality Assurance Program documented in the PSAR states, in part, that "activities affecting quality shall be prescribed by documented instructions ..."
Contrary to the above, on May 31, 1979, it was found that no written instructions had been developed for the operation or adjustment of pipe weld, heat treating equipment designed and built for use on safety related piping systems, including welds 1A, 2 and 3 of Burns & Roe isometric drawing RFW-419-5.7.
This is an infraction.
Action To Correct Deficienc On 8/6/79, Wright Schuchart Harbor/Boecon/General Energy Resou. ces, Inc., (WBG) terminated their contract (2808-215-113) with Seattle Industrial and assumed direct responsibility for the PWHT operations.
Action To Prevent Recurrence WBG has revised the PWHT procedure, purchased heat treating equipment from Cooperheat and developed and implemented a training program for the operators and inspectors. A packet containing the operating instructions and PWHT procedure are attached to the control panel of the equipment.
Page 2 of 4
Date Of Full Com liance Effective 9/12/79 WBG has been performing the PWHT operations. The PWHT has been witnessed by WBG guality Control Inspectors and,verified by a guality Engineer to assure compliance to the revised PWHT procedure, PWHT No. 1, Revision No. 9.
C. 10CFR50, Appendix B, Criterion XVII, states, in part, that "sufficient records shall be maintained to furnish evidence of activites affecting quality ...."
Paragraph D.2. 5 of the WPPSS guali ty Assurance Program documented in the PSAR states, in part, that "sufficient records will be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality..."
Contrary to the above, on Hay 31, 1979, it was 'found that sufficient had not been obtained to furnish evidence of satisfactory heat 'ecords treating of safety related pipe welding. For example, several heat treat record charts were illegible (e.g. welds 6, 7 and 8 of Burns 8 Roe isometric drawing No. RFW-419-4), thermocouple indications were not recorded on some portions of the recorder charts (e.g. welds 1A and 2 of Burns 5 Roe isometric drawing RFW-419-5.7), no operator names had been recorded on heat treating data records (e.g. welds 6, 7 and 8 of Burns 8 Roe isometri c drawing No. RFW-419-4, Welds lA, 2 and 3 of isometric drawing No. RFW-419-5.7) different and conflicting thermocouple Nos. had been recorded for the heat treatment of the same weld (e.g. the recorder chart's and certification sheets for weld 8 of Burns 5 Roe isometric drawing RFW-419-4, weld 1 of isometric FRW-418-7.8, welds 6, 7 and 8 of isometric RFW-418-4), different (and conflicting) dates of heat treatment had been listed on recorder charts and certification sheets (e.g. welds 4, 6, 7 and 8 of Burns 5 Roe isometric RFW-418-4, welds .1, 1A and 2 of isometric FRW-418-5.6).
This is a deficiency.
Action To Correct Deficienc WBG has initiated a program to review all completed PWHT charts and records for the PWHT conducted by. Seattle Industrial.. This review activity is overviewed by a guality Engineer who evaluates the findings.
Inspection Reports (IR's) are initiated as necessary to obtain resolution of the discrepancies found.
Action To Prevent Recurrence As noted in B above, WBG has assumed direct responsibility for the PWHT operation and has initiated a program to assure compliance to the revised PWHT procedure.
Page 3 of 4
Date Of Full Com 1 i ance The review of all records initiated by Seattle Industrial and the initiation of IR's for discrepant conditions is estimated to be complete by 4/1/80.
D. 10CFR50, Appendix B, Criterion V, states, in part, that "Activities affecting quality .... shall be accomplished in accordance with ...
instructions, procedures and drawings..."
Paragraph 3.2.5 of the WPPSS guality Assurance Program documented in the PSAR states, in part, that "... all project contractors for the nuclear related portions of the plant will be required to have a guality Assurance Program ... the program shall include the following items as ... applicable to the ... construction for which the contractor is responsible." Paragraph D.2.5.5 states, in part, that "activity affecting quality... shall be accomplished in accordance with ... procedures; "
I" Contract 215 Procedures No. PWHT-1 Revision 4 (entitled "Post Meld Heat Treat Procedure No. 1), specifies that heating and cooling rates above 800o F shall in no case exceed 400o F per hour for ASME Section III requirements.
Contrary to the above, on Hay 31, 1979, weld lA it was found that recorder chart of Burns 8 Roe isometric drawing No. RFW-419-5.7 and weld 6 and 7 (records are somewhat illegible) of isometric drawing No. RFW-419-4 indicate periods of time when the heating and co'oling rates exceed 440 F per hour.
This is an infraction.
Action To Correct Deficiencies RFW-419-5.7 Weld 1A: The review conducted- by WBG (see C above) has concluded that due to an excessive cooling rate (excess of 220o F per hour), the weld will be re-postweld heat, treated.-
RFW-419-4 Weld No. 6: Additional'weld repai r of this weld is required, therefore concurrent with the repair it will be re-postweld heat treated.
RFW-419-4 Weld No. 7: Final evaluation of Report IE-119 and the PWHT ata from Seattle Industrial has not been made.
Action To Prevent Recurrence As noted in B above, MBG has assumed di rect responsibility for the PWHT operation and has initiated a program to assure compliance to the revised PWHT procedure.
Date Of Full Com liance 4/1/80.
Page 4 of 4
I 8 RfgO C~
i 0 UNITED STATES v
~
NUCLEAR REGULATORY COMMISSION REGION V 1990 N. CALIFORNIA BOULEVARD v,
~o~ SUITE 202, WALNUT CREEK PLAZA WALNUTCREEK, CALIFORNIA94596 Docket No. 50-397 Washington Public Power Supply System P. 0. Box 968 Richland,'Washirigton 99352 Attention: Mr. N. 0. Strand Managing Director Gentlemen:
Subject:
NRC Investigation of Post Weld Heat Treatment at Washington Nuclear Project No. 2 (WNP-2)
This refers to the investigation conducted by Messrs. T. W. Bishop, G. Hernan-dez, and W. G. Albert of this office and Mr. P. E. Baci of IE Headquarters of activities authorized by NRC Construction Permit No. CPPR-93. The investi-gation was conducted, on May 17, May 29-June 1, June 11-14, and September 10-14, 1979, and concerned allegations of improper post weld heat treatment (PWHT) of welds at WNP-2. The findings of the investigation were discussed with Mr.
A. D. Kohler and other members of your staff following each segment of the investigation.
reexamination The areas examined during the investigation are described 'in the enclosed inves-tigation report. Within these areas, the invesiigation consisted of selective of procedures and representative records, interviews with personnel, observations by the inspectors, and independent metallographic testing of welds.
Based on the results of this inspection, it appears that certain of your ac-tivities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Yiolations, enclosed herewith as Appendix A. These items of noncompliance have been categorized into a level as described in our correspondence to all NRC licensees dated December 31, 1974.
This notice is sent to you pursuant to the provisions of Section 2.201, of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within thirty (30) days of your receipt of this notice, a written statement or explanation in reply including (1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
1 lt t
Washington Public Power Supply System In accordance wi th Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you believe to be proprietary, it is nec-essary that you submit a written application to this office, within 30 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the rea-sons why it is claimed that the information is proprietary. The application should. be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclo-sure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be glad to discuss them. with you.
Sincerely, G. S. S/encer, Chief Reactor Construction and Engineering Support Branch
Enclosures:
A. Notice of Violation B. IE Inspection Report No. 50-397/79-10 cc w/o enclosure 8:
M. E. Witherspoon, Division Manager equality Assurance, WPPSS W. C. Bibb, Manager WNP-2 Project, WPPSS
APPENDIX A Mashington Public Power Supply System P. 0. Box 968 Richland, Washington 99352 Construction Permit No. CPPR-93 NOTICE OF YIOLATION Based on the results of NRC inspections conducted between Hay 17 and September 14, 1979, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC facility license No. CPPR-93 as indicated below.
A. 10CFR50, Appendix 8, criterion IX, states, in part, that "measures shall be established to assure that special processes, including...heat treat-ing, ...are controlled and accomplished by...using qualified procedures..."
Paragraph D.2.5.9 of the MPPSS guality Assurance Program documented in the PSAR states, in part, that "measures shall be established...to assure that special processes, including...heat treating...are accomplished...using qualified...procedures..."
Contrary to the above, on May 31, 1979, it was found that the piping post weld heat treating procedure no. PMHT-1, revision 4 (entitled "Post Meld Heat Treat Procedure No. 1) was implemented using a unique method of heat application without the benefit of qualification. The method employed electric resistance heater blankets placed along each side of the weld
{approximately 14 inches from the weld center line) rather than directly over the weld. This procedure had been used to heat treat safety rela-ted pipe welds including welds 6, 7, and 8 of Burns & Roe isometric draw-ing no.'FM-419-4.
This is an infraction.
B. 10CFR50, Appendix B, Criterion V, states, in part, that "activities affect-ing quality shall be prescribed by documented instructions..."
Paragraph D.2.5.5 of the MPPSS guality Assurance Program documented in the PSAR states, in part, that "activities affecting quality shall be prescribed by documented instructions..."
Contrary to the above, on t1ay 31, 1979, it was found that no written in-structions had been developed for the operation or adjustment of pipe weld heat treating equipment designed and build for use on safety related piping systems, including welds 1A, 2, and 3 of Burns 5 Roe isometric dr awing RFM-419-5.7.
This is an infraction.
f t'
C. 10CFR50, Appendix B, Criterion XVII, states, in part, that "sufficient records shall be maintained to furnish evidence of activities affecting quality..." O Paragraph D.2.5. of the HPPSS guality Assurance Program documented in the PSAR states, in part, that "sufficient records will be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality..."
Contrary to the above, on Nay 31, 1979, it was found that sufficient rec-ords had not been maintained to furnish evidence of satisfactory heat treat-ing of safety related pipe welding. For example, several heat treat record charts were illegible (e.g. welds 6, 7, 8 of Burns 8 Roe isometric draw-ing no. RFH-419-4); thermocouple indications were not recorded on some portions of the recorder charts (e.g. welds 1A, and 2 of Burns 8 Roe iso-metric drawing RFH-419-5.7); no operators names had been recorded on heat treating data records (e.g. welds 6, 7, 8 of Burns 8 Roe isometric drawing RFH-419-4, welds 1A, 2, and 3 of isometric drawing no. RFH-419-5.7); different and conflicting therocouple numbers had been recorded for the heat treat-ment of the same weld (e.g. the recorder charts and certification sheets for weld 8 of Burns 8 Roe isometric. drawing RFH-418-4, weld 1 of isomet-ric RFM-418-7.8, welds 6, 7, 8 of isometric RHF-418-4); different (and conflicting)- dates of heat treatment had been listed on recorder charts and certification sheets (e.g. welds 4, 6, 7, 8 of Burns 5 Roe isometirc RFH-418-4, welds 1, 1A, 2 of isometric RFH-418-5.6).
This is a deficiency.
D. 10CFRSO, Appendix B, Criterion Y, states, in part, that "activities affect-ing quality...shall be accomplished in accordance with...instructions, pro-cedures, and drawi ngs..."
Paragraph D.2.5 of the HPPSS guality Assurance Program documented in the PSAR states, in part, that "...all project contractors for the nuclear related portions of the plant will be required to have a guality Assurance Program...the program shall include the following items as
...applicable to the...construction for which the contractor is respon-sible." Paragraph D.2.5.5 states, in part, that, "activity affecting quality...shall be accomplished in accordance with...procedures...".
Contract 215 procedure no. PSlT-1 revision 4 (entitled "Post Held Heat Treat Procedure no. 1), specifies that heating and cooling rates above 800 F shall in no case exceed 400 F per hour for ASiME Section III require-ments.
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Contrary to the above, on Hay 31, 1979, it was found that recorder chart for weld 1A of Burns 5 Roe isometric drawing no. RFlJ-419-5.7 and weld 6 or 7 (records are somewhat illegible) of isometric drawing no. RFM-4)9-4 indicate periods of time when the heating and cooling rates exceed 400 F per hour.
This is an infraction.
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U. S. NUCLEAR REGULATORY COMHISS ION OFFICE OF INSPECTION AND ENFORCE~sFNT REGION V Report No. 50-397 79-10 Docket No. License No. CPPR-93 Sazeguards Group Licensee: Washin ton Public Power Suo lv S stem P. 0. Box 968 Richland, Washin ton 99352 Faci1ity Name: Washinqton Nuclear Project No. 2 (WHP-2)
Inspection at: WNP-2 Site, Benton County, Washington Inspection conducted: l".ay 17, Hay 29-June 1, June 11-14, September 10-14, 1979 Inspectors: I.Q . i/ /'.
Date Signed W. Bishop, actor Inspector
> v/.t G. Hem ndez, eactor nspector Date Signed
(/zi/m Albert, actor Inspector Approved By:
W.
P<1 G.
f B ci:, estigator C a Oat Pagne R. T. Dodds, Section Chief at Signed Reactor Construction and Engineering Support Branch Su~ry:
Investi ation from Ha 17-September 14, 1979 Report 50-397/79-10)
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Areas Investioated: Investigation of allegations relating to post weld heat treatment oi a pipe weld and a pipe whip restraint.
The investigation involved 220 rganhours by three NRC inspectors, one inves-tigator, and two NRC consultants.
Results: Four items of noncompliance were identified during the investiga-
~tion three infractions or: failure to qualify the post <<aid heat treatment proce-dure, failure to provide procedures for equipment operation, failure to accomp-lish heat treatment in accordance with requirements; one deficiency or: failure to provide adequate quality records).
RV Form 219 (2)
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DETAILS
- 1. Persons Contacted
- a. Washinoton Public Power Supol S stem HPPSS) .
+A. D. Kohler, tOP-2 Project Manager .
- M. E. Witherspoon, Division Manager - Quality Assurance "A. M. Sastry, Project Quality Assurance Manager
- J. C. Janus, Construction Manager
- L. D. Noble, Mechanical Engineer
- J. D. Martin, Startup and Operations Manager J. N. Steidl, Sr. Quality Assurance Engineer
- 0. K. Lawrence, Quality Assurance Engineer
- b. Burns 5 Roe, Inc. B/R)
- G. T. Harper, Technical Support Manager
- N. J. Parise, Deputy Project Quality Assurance Manager L. F. Akers, Sr. Welding Engineer H. R. Tuthill, Sr. Quality Assurance Enginee~
J. A. Lauck, Quality Assurance Engineer
- Denotes those attending the exit interview on June I, 1979.
- c. . WSH/Boecon/Bovee and Crail/GERI WBG)
A. Larsen, Quality Assurance Manager L. Buckner, Quality Assurance Supervisor T. Bennington, Quality Control Supervisor R. Lawton, Quality Assurance Engineer L. Wulff, Quality Assurance Engineer In addition, three PWHT operators and one former QC supervisor were interviewed.
- d. Seattle Industrial Controlled Heat (SI)
'ed Giddens, Quality Control Manager In addition, two previous SI employees were interviewed.
- e. P bus Steel Com an D. Barnes, Quality Assurance Manager
- 2. Alle ations and Summar of Investi ation Results On May 4, 1979 the NRC Region V office received an allegation regarding the application of excessive and nonuniform temperatures in the postweld
t heat treatment of a pipe weld at klNP-2. The alleger stated that recording equipment had been manipulated so that the recording chart indicated that the heat treatment had been properly performed. The individual was inter-viewed by two NRC inspectors on Hay 17, 1979, at which time he provided two specific allegations:
Alle ation no. 1: One large pipe or penetration weld on a mainsteam or feedwater ine was subjected to a temperature of approximately 2000 F on the lower 180 of the weld, while the upper 180 of the w~ld was held at; the normal heat treating temperatures (approximately 1150 F). The thermocouple leads to the temperature recorder were manipulated so that the recorder chart indicated proper post weld heat temperatures for both the bottom and top of the weld. This was accomplished by disconnecting the thermocouple from the bottom of the weld and splitting the signal from the, properly reading, top thermocouple.
~Findin The allegation was not substantiated.
The alleger was interviewed on two later occasions when he furnished addit-ional information regarding the location of the welds and the alleged techniques used in manipulating equipment. The pipe weld in question was determined to be a 24 inch feedwater pipe weld no. 7 on Burns 5 Roe isometric drawing RFlt-418-4 or weld no. 7 on Burns 5 Roe isometric draw-ing RFM-419-4. Interviews with cognizant equipment operators, current and former Seattle Industrial personnel, and contractor quality surveill-ance personnel failed to substantiate the allegation. An examination of heat treatment records associated with the two welds in question did not substantiate the allegation, but did reveal some irregularities in-cluding: illegible post weld heat treat recorder charts; temporary loss of one thermocouple indication on one chart; record inconsistencies re-garding thermocouple identification numbers; inconsistent dating of one P>lHT certification sheet. Due to the nature and scope of 'the record irregularities identified it was concluded that independent NRC metallo-graphic testing of the two welds was warranted. The testing included in situ hardness tests and ~icroscopic examination for grain size irreg-ularities. This testing was accomplished in September 1979 by a NRC contractor. The final contractors report (NRC no. IE-119) was received in Region Y in Oecember 1979. Based on the results of these tests it was concluded that there was no evidence of radically excessive or non-uniform post weld heat treatment. The maximum temperature reached at any point was estimated to be in the range of 1270 -1310 F. Some non-uniformity was noted but the maximum temperature differential around the perimeter of the weld zone and pipe is estimated to be less than 100 F. As indicated the metallographic testing did not substantiate the allegation.
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Allegation no. 2: While performing post weld heat treatment on a to vary between 650 and 1650 F during the soak period. A section of F.
l large the recorder chart which showed the excessively high temperature was cut out before the chart was presented to the customer.
11 d Findinci The allegation was not substantiated.
Additional interviews with the alleger enabled identification of the struc-ture in question, which was determined to be a large pipe whip restraint (mark no. 316Pl) for the mainsteam piping system. Personnel interviews and examination of quality records (including heat treat charts) failed to substantiate the allegation. The investigating team was unable to identify any charts which showed evidence of cut out sections.
While 'the two allegations were not substantiated, several significant concerns were identified with the post weld heat treatment program. These concerns are identified in paragraph 3 and were first reported to licen-see representatives on June 1, 1979. A stop-work order, preventing urther quality class 1 heat treatment by the subcontractor, was issued by the licensee on that date. As of December 1979, the subcontractor involved (SI)had not been allowed to resume heat treatment of safety related components.
1 Investi ation of the Alle ations Post weld heat treatment of large piping at the NNP-2 site is included in the prime mechanical and piping contract (contract 215). This contractor had subcontracted piping heat treatment to Seattle Industrial Controlled Heat, Inc., of Seattle, Washington. The investigation was initiated at the WHP-2 site on tray 29, 1979. It was determined that, as of that date, the post weld heat treatment subcontractor had heat treated approximately 20 safety related pipe welds (all of these welds were in the mainsteam and feedwater piping systems). It was also determined that the subcon-tractor had completed heat treatment of large pipe whip restraints for the tNP-2 project at Pybus Steel Company. The investigation included an examination of the procedures applied. to post weld heat treating by the subcontractor, interviews with personnel, examination of quality records
'associated wi th heat treatment, and independent metallographic examinations of suspect pipe welds. The results were as indicated below.
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- a. Oualit Assurance ImDlementin Procedures It was found that the heat treat subcontractors quality assurance manual had not yet been approved by the Construction Manager (Burns 5 Roe) a'nd the subcontractor had been, directed to work under the requirements of the previously approved prime contractors guality Assurance t1anual. The inspectors examined the procedures invoked for post weld heat treatment for compliance to the requirements 'of the pertinent gA manual, the contract specification, the AMS struc-tural welding code, AMS 0.1.1 and the ASME Section III code (as applicable), and the PSAR.
The procedures examined were: "Post Meld Heat-Treat Procedure No. 1",
PMHT-1, revision 4; "Preheat and Post-Meld Heat Treat Procedure no.
7891", PPMHT-7891, revision 0; and "Melding and Sequence Procedure no. 1", MSP-1, revision 1.
Procedure PMHT-1, above, applies to pipe heat treatment. This pro-cedure was supplemented with a one page training document describ-ing how heaters, thermocouples, insulation, and connections are to be made. This supplemental document was not numbered, dated, nor did it have any approving signatures. PPMHT-7891 and MSP-1 apply to pipe whip restraints fabricated by Pybus Steel Company. The examination disclosed the following concerns:
(1) Procedure PMHT-1 was not qualified.
PMHT-1 employs a unique method of post weld heat treatment wherein the resistence heater blankets are not placed direct-ly over the weld to be heat treated. The resistance blankets are placed on each side of the weld (at a distance of approx-imately 1~ inches from the weld). Heat conduction through the pipe wall heats the welds to the PMHT temperatures. Con-trary to the requirements of 10CFR50 appendix B', criterion IX, which requires the qualification of special processes such as heat treating, no qualification tests were conducted to assure that this- process properly heat treated the pipe welds.
The lack of qualification testing does not enable assessment'hat the entire weld, especially the root, rechives adequate time at temperature nor is it possible to determine if the area of the pipe directly under the heaters is subjected to excessive temperatures. The failure to properly qualify the heat treatment procedure is an apparent item of noncompliance (50-397/79-10/01).
(2) Procedures for operating PNHT eauipment were not developed.
The equipment had been designed and built- by the subcontractor and no specific instructions for adjustment or operation had been written and provided to the equipment operators. Such proce-dures were necessary to identify how to control the rate of heating and cooling. The failure to provide implementing i,n-structions or procedures is contrary to 10CFR50, Appendix 8, criterion V and is an apparent item of noncompliance (50-397/
79-10/02).
- b. Interviews with Personnel Personnel involved with the conduct and surveillance of post weld heat treatment operations were interviewed. This included the on-site Seattle Industrial representative, former Seattle Industrial personnel, heat treatment equipment operators, and current and former gA surveillance personnel. The individuals were questioned regarding the alleged practice of manipulating equipment or record charts, record irregularities, and any other improper actions. Hone of the individuals provided any information which would substant-iate the allegations.
Ho other'items of noncompliance or deviations were identified.
C. Observations of Heat Treatin Operations, Pipinq, and Structural Stee While no post weld heat treatment of safety related components was in progress during the investigation several non safety related pipe welds were being heat treated. The procedures, and techniques for PllHT were the same for safety related and non-safety related compon-ents. The in-process heat treatment for two non safety related pipe welds were observed. The heat treatment activities appeared to be in compliance with the requirements of procedure PMHT-l. The inspec-tors also visually examined the pipe welds no. 7 of RFH-418-4 and RF'l<-419-4, and pipe whip restraint no. 316P1 for any visual evidence of excessive or radical post weld heat treatment. The visual exam-ination of the two pipe welds and restraint 316P1 did not identify any defects.
Ho items of noncompliance or deviations were identified.
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- d. Review of Oualit Records The inspectors reviewed the quality records associated with the oost weld heat treatment of safety related pipe welds and selected pipe whip restraints performed by the subcontractor. This included an examination of weld history records (HF-6 form), PMHT certifi-cates, PMHT Log, P!NT Inspection Checklists, PMHT Oata Sheets, PMHT Time/Temperature Recorder Charts, and pertinent nonconformance re-ports and surveillance reports. The records of heat treatment of pipe welds were examined at the MHP-2 site while the records for heat treat-ment of the pioe whip restraints were examined at the Pybus Steel Company, in 'Wanatchee, Mashington. The examination revealed two areas of concern as indicated below:
(1) Sufficient records were not maintained to furnish evidence of proper post weld heat treatment.
Several of the heat treatment charts were illegible to the degree that the thermocouple numbers could not be identified (e.g. welds 6, 7, and 8 of isometric no. RFM-419-4, and welds 1, 1A, and 2 of isometric no. RFM-418-5.6). Thermocouple in-dications were not recorded on some portions of the recorder charts'(e.g. welds'A and 2 of isometric no. RF!<-419-5.7). There were. inconsistencies on charts and certification sheets for thermocouple identification numbers (e.g. weld 8 of isometric no. RFM-418-4, weld 1 of isometric no. RFM-418-7.8, welds 6, 7, 8 of isometric RFW-418-4). Ho operators names had been recorded on data records (e.g. weld 6, 7, 8 of isometric RF!(-419-4, welds lA, 2, 3 of isometric RFM-419-5.7). There were incon-sistencies in the date of heat treating as shown on certifi-cation sheets and the recorder charts (e.g. welds 6, 7, 8 of isometric no. RFM-418-4, welds 1, lA, 2 of isometric no. RFM-418-5.6, weld 4 of isometric RFM-418-4). The failure to main-tain sufficient quality records to furnish evidence of proper post weld heat treatment is contrary to the requirements of 10CFR50 Appendix B. This is an apparent item of noncompliance (50-397/79-10/03 ).
(2) Records indicate heating and cooling rates exceeded procedure and ASIDE code limitations (no more than 400 F/hr).
Recorder charts for weld 6 or 7 (Note: Records were somewhat illegible) of isometric no. RFM-419-4 and weld 1A of isometric no. RFM-419-5.7 indicate that for shor) periods of. time the heating and cooling rates exceeded 400 F/hr. The failure to accomplish heat treatment in accordance with procedures. is contrary to the requirements of 10CFR50 Appendix B. This is an apparent item of noncompliance (50-397/79-10/04).
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It was also found from the records examination that the sub-contractor representative on site would function as the job suoervisor and sign certifications as the quality control representative. Contractor representatives stated that al though the subcontractors representative signed certificates using the title "gC" he did not perform quality control functions. This responsibility had been retained by the prime contrac or.
e, Independent t1etal1oaranhic Testin Because of the nature and scope of the record irregularities, it was concluded that independent HRC metallographic testing of the two pipe welds allegedly improperly heat treated was warranted.
The 8RC contracted the services of Parameter, Inc., of Elm Grove, llisconsin to perform in situ hardness tests and microscooic examina-tion of welds 7 of isometric drawings nos. RF!<-418-4 and RFH-419-4.
These welds join the feedwater line to the isolation check valve inside the containment vessel. Hardness tests were conducted on the weld, heat, effected zones of the pipe and valve, and uneffected areas of the pioe and valve. Approximately 75 locations were examined for hard-ness with 15 tests at each location. t1icroscopic examination of the welds, heat effected zones, and unaffected pioe and valve were made in 17 locations. As stated in paragraph 2, above, there was no evidence from the testing which would substantiate the allegation
. of radically excessive or non-uniform heat treatment. During the examination, however, one area was located on valve RFH-Y-10A which apoears to have a different temperature history than other portions of the valve body examined. The area is located approximated 60 counter clockwise from the top of weld no. 7 on the valve body a distance of approximately 8 inches from the weld centerline. The area aopears to be a weld repair. It was concluded from microscopic examination that the repair was made after the valve was quenched and tempered and that the area was never subsequently heated to above the lower critical temperature o the material (approximately 1330 F).
The significance of this condition will be examined during subse-quent inspections. This item is unresolved (50-397/79-10/05).
- 4. Hanaaement Interviews The inspectors and investigator met with licensee and Burns and Roe rep-resentatives on June 1, 1979, June 13, 1979, and September 13, 1979 and sumiarized the scope and findings of the investigation. Licensee repre-sentatives were advised of the results of metallographic testing on Oc-tober 26, 1979 following receipt of the draft renort by the tlRC contractor.
Licensee representatives were responsive and stated that immediate action would he taken to resolve the concerns identified.
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