ML17275B095
| ML17275B095 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/30/1981 |
| From: | Burdoin J, Dangelo A, Dodds R, Elin J, Fox D, Haist D, Narhut P, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17275B090 | List: |
| References | |
| 50-397-81-03, 50-397-81-3, NUDOCS 8106260425 | |
| Download: ML17275B095 (53) | |
See also: IR 05000397/1981003
Text
~ ~
~j
U. S.
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION
AND ENFORCEMENT
REGION
V
Report
No. 50-397/81-03
Docket
No'. 50-397
License
Ho.
CPPR-93
0
Licensee:
Washington Public Power Supply System
P. 0.
Box 968
Richland,
99352
Facility Name:
Nuclear Project
No.
2
(WNP-2)
Inspection at:
WHP-2 Site,
Benton County, Washington
Approved By:
Inspection
conducted:
February 10-13, 17-21, 23-27 and March 2-6, 9-13,
1981
Inspectors:
. /. ~
'1~~
D.
P.
H est,
Reactor Inspector
Date
Soigne
2/!
-2 S
. F.
ox,
cto
Inspector,
Region IV
Date Signed
~if 6
L:
0-ze-e~
ar ut, Reactor
Inspector
ate
S gne
9-ze-8f
. Wagner,
eactor Inspector
Date
S gne
'.
F. Burdosn,
Reactor Inspector
Date Signed
4
-z~-Sz
. J.
n e o
eactor
Inspector
Date
S gne
-x7- 54
0.
E
n, Reactor Inspector
Date
S gned
Fy
. T.
Do
s,
C se,
Reactor Projects
Section
1 Date
S gne
Reactor Construction Projects
Branch
Surrmary:
Ins ection durin
the
eriod of Februar
10-13
17-21
23-27
and March 2-6
and
-1
1981
Re ort No. 50-39
1-
3
.
Areas Ins ected:
Routine,
unannounced
inspection
by regional-based
inspectors
nc
u sng one Region
IV inspector) of construction activities including:
licensee
action on previous enforcement
items and inspection findings; preparation
for repair of deficiencies
in the sacrificial shield iva11; onsite design
activities; maintenance of safety-related
mechanical
and electrical
equipment;
licensee
action in response
to a
10 CFR 50.54(f) request,
and continuation
of an investigation of allegations of falsification of weld records.
~I
p
~
TL
- . ~b)
f"e
Surrmary (cont. )
<<2
The inspection
involved 313 inspector-hours
onsite
by 7
NRC inspectors.
Results:
Two items of noncompliance
were identified in the areas of drawing
control (paragraph
BB) and maintenance of installed safety-related
equipment
(paragraph
6).
ll
~ 1
~I
DETAILS
1.
Persons
Contacted
a ~
Washin ton Public
Popover
Su
1
S stem
(I.,2,4)
s)
1,2,3,4)
Il-5)
I1)
1,2,4)
I)
1,4,5)
I1,2I4)
2,4)
4,5)
4
3,4.5)
4)
(5)
3,5)
W.
R.
R.
B.
J.
P.
P.
T.
R.
M.
A.
G.
G.
E.
J.
J.
R.
J.
A.
W.
L.
W.
0.
G.
D.
L.
L.
C.
J.
J.
R.
C. Bibb, Project Manager
G. Natlock, Program Director
T. Johnson,
Project guality Assurance
Manager
A. Holmberg,
Deputy Project Manager - Engineering
Thorpe, guality Assurance
Engineer
W. Harness,
Field Engineering
Manager
I. Verrios, Manager-Vendor Audits
P.
V. Naidnient, Project Nanagement
J. Schutte,
Program Manager
A. Clinton,
PEN Specialist
(Acting)
M. Sastry,
Deputy Project Nanaaer - Systems
Turnover
I. Wells, Deputy Project Manager-Construction
K. Afflerbach, Deputy Project Manager-Startup
Carlson,
Equipment Maintenance
Coordinator
Hedges,
Plant Naintenance
Supervisor
Landon, Test Group Supervisor
Helgeson, guality Assurance
Engineer
J. Bufis, Startup Test Group Supervisor
N. Kugler, Licensing Manager
G. Keltner, Assistant Construction
Manager
R. Travis, Controller
G. Conn,
Design Engineering
Manager
P
K. Earle, Licensing Engineer
Brastad,
Lead Instrumentation
and Control Engineer
Baker, guality Assurance
Engineer
Price,
Task Force
Team Leader
Floyd, guality Assurance
Engineer
Wright, guality Assurance
Surveillance
Lucas, guality Assurance
Engineer
D. Hartin, Plant Manager
Spence, guality Assurance
Records
Supervisor
b.
Burns
and
Roe
Inc.
88R)
(I,4)
(1)
(4)
G.
J.
R.
M.
S.
H.
S.
T. Harper Jr., Technical
Support
Manager
N. Blas,
Home Office guality Assurance
Manager
C. Root, Assistant Project Manager
A. Lacey, Project Engineer
H. Rifaey, Field Group Supervisor-Mechanical
Burszein,
Lead Designer, Drafting
Salpute,
Field Group Supervisor-Electrical
-2-
(~)
(~)
(1)
(i)
C.
W. P. Gabriel, Senior Squad Leader-Drafting
F.
S. Weingard,
Lead Engineer,
Mechanical/Nuclear
H.
R. Tuthill, Assistant Quality Assurance
Manager
R.
D. Carmichael, Quality Assurance
Engineer
G. L. Baker,
Lead Quality Engineer
L. Glass, Quality Assurance
Engineer
R. Sanan, Civil Engineering Specialist
F. Weingard,
Lead Nuclear/Mechanical
Engineer
J.
A. Forrest, Project Director
L. E. Pokos,
Construction
General
Superintendent
M. L. Bursztein, Assistant Resident Project Engineer
J.
G. Propson,
Lead Electrical Engineer
T.
Neuman, Quality Assurance
Engineer
Gilber t Coomnweal th Associates
G C)
N.
R. Barker, Vice President
and General
Manager, Quality Assurance
Division
D.
N. Brown, Project Manager
H.
M. Flynn, Project Administrator
R.
E. Maudlin, Quality Assurance
Program Manager
D.
H. Nelson,
Employee Relations
Manager
C.
R. Witherell, Supervising
Engineer
B. J.
Watson, Site Manager
d.
WSH Boecon
GERI
WBG
P. Webster, Quality Engineering
Documentation Supervisor
J. Marr, Project Training Coordinator
J.
Robanske,
Maintenance
Engineer
I4)
e.
State of Washin ton
Marvin Moore, State
Examiner,
Washington State Auditor's Office
G. Hansen,
Operations
Division Chief, Energy Facility Site Evaluation
Council
(EFSEC)
f.
Bonneville Power Administration
W. Chin, Project Engineer
g.
Bechtel
Power Cor oration
Bechtel)
T. Mangelsdorf, Project Manager
S.
A. Giusti, Project Engineering
Management
~I
g
-3-
(4)
h.
General
Electri c
J.
H. Miller, Resident Site Manager
D. Becker, Technical Advisor
Pittsbur
h Des Moines
Inc.
PDM)
F. Warrington, Project
Manager
T. Foley, guality Assurance
Manager
R. Jones,
Welding Engineer
K. Conrad, Training Coordinator
M. Thompson, Ouality Control Supervisor
F. Lynch, guality Control Supervisor
J. Gabriel,
General
Foreman
In addition, interviews were held with various craft and quality assurance
personnel
and members of the Reverification of Completed Safety Related
Work
(RCSW) Task Force.
1.
2.
3.
4,
5.
Denotes
attendance
at management
interview on February
13,
1981.
Denotes
attendance
at management
interview on February 20,
1981.
Denotes
attendance
at management
interview on February 27,
1981.
Denotes
attendance
at management
interview on March 6,
1981.
Denotes
attendance
at management
interview on March 13, 1981.
The llRC Senior Resident Inspector,
Nr. A.
D. Toth attended all management
interviews.
2.
Site Tour
Feb rugr
17
1981
The inspectors
conducted
a site tour inspection during day shift to
observe
work activities at the Sacrificial Shield Wall girth weld preparation.
The tour also included observations of the general
state of housekeeping
and safety related
equipment maintenance.
One item of noncompliance
regarding maintenance of installed equipment
was identified and is discussed
in paragraph
6.
March 2
1981
The inspectors
conducted
a detailed site tour during the week of March
2-6,
1981, to observe
the control of work activities in progress,
the
physical condition of safety related equipment,
and the general
state
of housekeeping.
Housekeeping
was noted to have substantially
improved
on the site within the last few months but this may be attributed to
the greatly reduced construction activity level.
The following
conditions were identified.
~ I
(a)
(b)
(c)
A bottle labeled
"Soda" was resting
on an electrical termination
box above the division 2, safety related,
+ 24 volt batteries.
The licensee
stated that this solution is used to neutralize
spilled battery acid.
The inspector pointed out the possibility
of spilling this solution on the safety related battery.
The bottle
was
removed from the battery area.
Cable trays
and installed cables
appeared
to be satisfactorily
maintained with respect
to storage
and housekeeping
requirements.
However,
an electrician's tools and personnel
items were found
lying on installed safety related cable in the cable spreading
room.
This appeared
to be an isolated instance,
and the licensee
took prompt corrective measures.
Standby service water
pump SH-P-1A (division 1, safety related)
and high pressure
pump HPCS-P-2 (division 3,
safety related)
were observed
on Narch 4,
1981 to have de-energized
space
heaters.
This was
an item of noncompliance first observed
by
NRC inspectors
on February
17,
1981 (discussed
in Paragraph
6
of this report)
and discussed
with the licensee at the February 20,
1981 management
meeting.
Apparently no action
had been taken
by
the licensee to correct this ongoing
NRC concern.
This was pointed
out to the licensee's
quality assurance
organization
and the
MPPSS
electrical superintendent
on the morning of thatch 5,
1981.
By
the afternoon of March 5, 1981, temporary circuits were installed
to provide power to the motor space
heaters.
The inspector noted
at the exit meeting
on hiarch 6, 1981, that
some groups within the
licensee's
organization
seemed
unable to bring sufficient attention
to bear
on identified
NRC concerns
to promptly correct ongoing
situations
which are adverse
to safety related
equipment reliability.
This item of noncompliance will be examined during future inspections.
3.
Licensee Action on Previous
Enforcement
Items
a ~
(Closed
Yiolation
50-397 79-12 04
Ga
s and Shims
Between Sacrificial
1e
Sect
ons
an
e
e orta
e
e icsenc
ate
October
19
This noncompliance is due to the failure to join the upper
and lower
segments
of the sacrificial shield wall in accordance
with drawings
and erection
procedures
(IE Inspection
Report
No. 50-397/80-04).
The corrective action plan for the sacrificial shield wall is described
in licensee letter
G02-80-79.
The plan is to provide
a partial
groove weld with fillet weld reinforcement to be installed
along the exterior circumference
between
the upper and lower ring
assemblies
at elevation 541'-5".
Implementation of this corrective
action plan is currently in-process
in accordance
with MBG Work
Procedure
No.
170 "Sacrificial Shield Hall Girth Meld".
The inspector
reviewed this work procedure
and visually examined
the sacrificial
shield wall girth weld joint preparation activities for compliance
to licensee
coranitments
on this repair.
This item is closed.
(Closed
Noncompliance
50-397 80-04
01
Failure to Provide
A
roved
rocedures
or t e Conduct of
U
Examsnatsons
Ultrasonic Test procedure
gCP 8.0 Rev.
1 was approved
by the licensee
on September
22,
1976 for examination of sacrificial shield wall
components.
However,
UT test reports indicated sacrificial shield
wall component examinations prior to that date.
The inspector
reviewed evidence
showing that these ultrasonic examinations
were
performed to a "reviewed and tentatively approved" revision,
gCP
8,
Rev. 0.
This item is closed.
(Closed
Noncom liance
50-397 80-04
07
Shield Wall
ualit
Records
ot
ccurate
Identif
Ins ection Personne
The licensee
has reinspected
portions of the sacrificial shield
wall that are accessible.
The results of this effort are reported
in the sacrificial shield wall Evaluation Report of August I, 1980
(Section III.C.5).
Defects were identified in
12% of the accessible
It was concluded that most of these defects
and their projections
to inaccessible
welds will not be detrimental to the performance
of the sacrificial shield wall.
For the inaccessible
welds, the
licensee
performed
a bounding defect assessment
which enveloped
both known and postulated
defects.
The analysis
concluded that
failure by plastic collapse will not occur based
on the low probability
(<1/) of occurrence of critical size defects
and the existence of
multiple load paths (Sacrificial Shield Wall Report,Section I.B.3).
This item is closed.
Closed
Noncom liance
50-397 80-04
10
Uncertified Personnel
ervorme
on estructsve
xaminatson
on t e Sacn
c a
S
e
Wall.
This is identified in the Sacrificial Shield Wall Report
as Concern
No. 5.
The licensee
has performed reinspection of accessible
portions
of the Sacrificial Shield Hall.
The report concluded that the
nondestructive
examinations
performed
by these uncertified personnel
has not affected the quality of the welds in the sacrificial shield
wall.
The known and postulated
defects
are addressed
in Section
III.D of the Sacrificial Shield Mall Report under the bounding
defect structural
assessment.
This item is closed.
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~ 1
I
e.
Closed
Noncom liance
50-397 80-04
12
Re airs
on Sacrificial
Shse
d
Wa
Not Performed
n Accor ance wit
AWS Dl.l.
This is identified in the Sacrificial Shield Wall Report as
Concern
No. 28.
Four repairs of cracks in sacrificial shield wall shop
welds did not comply with AWS D1.1 repair requirements.
Two of
these weld repairs
areas
are accessible
and weve ultrasonically
examined resulting in no defects or indications.
The other two
weld repairs
are inaccessible
for examination
and their potential
defects
are enveloped
in the bounding defect assessment
in Section
III.D of the Sacrificial Shield Wall report.
This item is closed.
f.
0 en
Noncom liance
50-397 79-10 01
Failure to Pvo erl
ualif
ost
We
Heat Treatment
Proce ure
The thermal transient analysis
performed
by the licensee
to qualify
the post weld heat treatment
procedure
used
by Seattle
Industrial
disclosed that the temperature
under the heater blanket would have
exceeded
code allowable and lower critical temperatures.
In addition,
the licensee's
thermal analysis
assumed
no air flow through the
pipe f'r the case of a 12.0
KW heater blanket.
Air flow through
the pipe would result in increased
temperatures
under the heater
blanket.
The licensee relied upon field tests of two welds
(weld no.
7 on
drawing no.
RFW-418-4 and weld no.
7 on drawing no.
RFW-419-4)
performed
by
NRC consultants
to conclude that the heat treatment
method did not result in excessive
ov non-uniform temperatures
at
the surface of the weld joint.
The inspector
pointed out that
the
NRC field tests
were commissioned
to determine the validity
of allegations that temperatures
of 2000
F weve reached
on portions
of these specific pipe welds and not to qualify the contractor's
post weld heat treatment
procedure.
~'I
1
The inspector
requested
that the licensee
take
a coordinated
engineering
approach to the qualification of this procedure.
The licensee
committed to: (1) complete the thermal analysis
assuming
a 12.0
Kl! heater
and
an appropriate air flow through the pipe;
(2) justify
thermal results
which are inconsistent with code allowable temperatures;
and (3) verify that the assumptions
and analysis
are consistent
with the post weld heat treatments
performed
by Seattle Industrial,
e.g.,
same material
types
and thicknesses.
This item remains
open.
(Closed
Noncompliance
50-397 80-01 02
Failure to Control Lfeld
er
atersa
n
ccor ance ant
Procedures
Instances of uncontrolled weld filler material
and improper control
of portable weld rod ovens were identified by the inspectors.
The licensee replied to this noncompliance in letter no.
G02-80-150
.dated July 11,
1980 stating that
a directive was issued to all
contractors
performing welding activities to conduct training sessions
on the proper control of welding activities.
The inspector confirmed
that this directive had been
issued
and sampled the contractor's
records for compliance to the directive.
In all cases
examined,
the training had been accomplished
as required.
This item is closed.
(Closed
Noncom liance
50-397 80-16 07
Failure to
Re ort 10
CFR
e
Item
The licensee
had failed to report that the seismic qualification
tests for llestinghouse
switchgear did not assume rigid conduit
connections
at the top of the equipment which is the manner in which
the conduit is installed.
The licensee
responded to this item of noncompliance in letter no.
G02-80-269 dated
November
26, 1980.
The licensee stated that all
known construction deficiencies
have
been
reviewed for reportability
and that
a Project
Management Instruction would be issued to formalize
the policy in effect for reporting
by December 5,
1980.
The inspector found that the Project
Management Instruction
No. PMI-4-10, Revision
2 had not been issued
as of March 6, 1981,
but was ready for signature
by the Project Manager.
The licensee
guality Assurance
Manager indicated that
a computerized
system is
being implemented to track conmitments to the
NRC and to ensure
that the
NRC is informed when commitments will.not be met.
It is
expected that the first phase of this system,
which will include
comitments
made in correspondence
to the
NRC will be operational
in April, 1981.
Commitments
made in 50.55(e) reports
and inspection
reports v(ill be included in the tracking system in later phases.
This system will be examined in a subsequent
inspection.
~
'r
The inspector
examined Project
Management Instruction
No. PMI-4-10,
Rev.
2 for compliance with the
NRC guidelines
on reporting potential
50.55(e)
items.
This instruction appears
to adequately reflect
the
HRC guidelines with an additional clarification that two senior
level licensee
represen(atives
have responsibility for determining
the reportability of nonconformance
reports or other notifications
that lower tier contractors
or lower level personnel
consider to
be potentially reportable.
This determination is made within one
week and serves
to screen
out items that are not considered to
be reportable or potentially reportable.
The licensee's
analysis
of the seismic
adequacy of Westinghouse
switchgear with rigid conduit
and the results of in situ testing will be available at the site
for examination
by the
NRC seismic qualification review team.
This item is closed.
4.
Licensee Action on Previous
Ins ection Findin s
a ~
Closed
Unresolved
Item
50-397 79-16 01
Modification of Plans
to
ssess
Concrete
Voi sn
The licensee's
plan for assessment
of concrete
voiding in the sacrificial
shield wall was approved in April 1979.
As reported in IE Inspection
Report
Ho. 50-397/79-08
the primary approach in investigating for
voids in concrete will consist of examination during startup
and/
or operation,
using the reactor core as
a neutron
and
gamma source.
Since this plan was approved, additional concrete voiding was observed
causing the licensee
to reevaluate
the proposed
plan.
The inspector
was able to determine,
through discussions
with licensee engineering,
that the originally proposed
pl'an of using the reactor core
as
a neutron
and gama
source for the investigation of the concrete
voids is still in effect,
This item is closed.
5.
Onsite
Desi
n Activities
a ~
General
This portion of the inspection
was performed with the assistance
of the
NRC Region
IV Vendor Inspection
Branch principal inspector
assigned to Burns
and
Roe.
The licensee
was informed that as
a
result of the substantial shift of engineering activities to the
site, the
NRC Region
V office will assume
the responsibility for
inspections of Burns and
Roe design activities with the support
of Region
IV inspectors
as necessary.
The licensee
was also informed
that currently open
Region
IV inspection
and enforcement
items
will be transferred to the
WNP-2 Docket Ho. 50-397 and that future
enforcement
actions will be administered
through Docket Ho. 50-397.
~ ~
-9-
b.
Desi
n Process
Mana ement
(1)
The objectives of this area of the inspection were to determine
that:
a.
Procedures
have
been prepared,
approved
by the contractor,
and issued to prescribe
a controlled system for the management
of the design
process that is consistent with the commitments
of the
WNP-2 guality Assurance
Program.
b.
The procedures
for control of the design
process
are being
properly and effectively implemented
by the contractor.
(2)
Burns
and
Roe
The inspector
examined the following Burns and
Roe design control
procedures
and representative
design
documents
to accomplish
~ the objectives identified in section
B. 1 above.
Procedures
Reviewed
WNP-2-007,
Design
Change Control System
WNP-2-017, Project Engineering Directive (Field)
WNP-2-018,
Drawing Control
Log (DCL) and Specification
Control
Log (SCL)
WNP-2-019, Project Engineering Directive
(Home Office)
WNP-2-ED-001, Engineering
Review and Approval of Project
Drawings
WNP-2-ED-009, Review, Certification and Approval of Tech.
Specs
WNP-2-ED-010,
Cal culati ons
WNP-2-PM-016,
Review and Approval Signature
Requirements
Documents
Examined
One (1) corrective action request
Forty five (45) electrical
and mechanical
drawings
Four (4) internal
memorandum
One hundred five (105) project engineering directives
Two (2) specifications
Three
(3) technical
memorandum
The inspector identified drawing nos.
M-601, M-611, M-630,
M-805 and E-539-52 which were'ot revised
when the drawing
control log identified five (5) or more project engineering
directives with assigned
business
documents or at least
one
(1) project engineering directive outstanding for longer than
three (3) months
as required
by Project Instruction
No. WNP-2-018.
The failure to update
drawings in accordance
with quality
procedures
is considered
an apparent
item of noncompliance
with 10 CFR 50, Appendix B, Criterion V, Instructions,
Procedures
and Drawings.
(50-397/81-03/01)
~ ~
~ ~
-10-
(3)
Gilbert
Commonwealth Associates
The inspector examined the following (Gilbert) Commonwealth
Associates
design control procedures
and representative
design
documents to accomplish
the objectives identified in section
B. 1 above.
Procedures
Pevi ewed
Applicable sections of WPPSS/gA Contract
No. C-0208, Sections
2.c, 3.c and 5.c of the Gilbert/Commonwealth
Nuclear gA Manual,
applicable sections of the
WNP-2 Project
Management
Manual
G-020,
Twelve (12) Design Control Procedures
(1.20, 1.30, 1.50, 2.05, 2.10,
2.25, 3.10, 3.15, 5.10, 5.15, 5.25, 5.30)
and applicable sections
of the WPPSS/WBG/Commonwealth
Associates
interface
document.
Documents
Examined
Nineteen
(19) calculations
One (1) computer log sheet
Ten (10) computer program verification summaries
Six (6) design verification document
packages
Nine (9) small bore pipe hanger
and support drawings
One (1) specification
Ten
10) supplier transmittal
forms (used to transmit verified WBG
drawings from Commonwealth Associates
to Burns
and
Roe
Six (6) vendor/contractor
drawing transmittal
forms
(used
to transmit
WBG drawings to Commonwealth Associates
The inspector identified that procedures
were not established
to control the utilization of the on-site
Radio Shack
Model II
computer
and associated
computer
programs
to perform safety
related calculations
and other design activities in a planned,
controlled and orderly manner.
(Gilbert) Coranonwealth
Associates
management
stated that an
approved
procedure to control the utilization and periodically
(weekly) verify the accuracy of mini-computer systems
(such
as the Radio Shack
Model II computer)
and associated
computer
programs will be in place
by March 15,
1981.
Although no
readily apparent errors were observed in safety related calculations
performed
on the Radio Shack
Model II computer,
a definite
uncertainty exists about those
performed prior to December
8,
1980 (the date the weekly computer
check and problems
run log
were initiated).
In view of this uncertainty,
(Gilbert) Commonwealth
Associates
Management stated that they would verify the accuracy
and adequacy of a random ten (10) percent
sample of calculations
performed prior to December 8, 1980,
by March 15, 1981.
Should
substantive
errors
be uncovered,
a plan and schedule for the
verification of all affected calculations will be developed
by March 15,
1981.
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(1)
The objectives of this area of'he inspection
weve to determine
that:
a.
Procedures
have
been prepared,
approved
by the contractor,
and issued to prescribe
and document
a program of indoctrination
and training,
and retraining, of both
new and reassigned
employees
conducting safety related activities at WNP-2.
b.
The procedures
are consistent with the commitments of
the
WNP-2 guality Assurance
Program and are being
properly and effectively implemented
by the contractor.
(2)
Burns
and Roe,
The inspector
examined the following WPPSS
and
Burns and
Roe
training procedures,
identified training requirements,
and
personnel
training records:
WNP-2 Project Instruction-Project Indoctrination
& Training
Section
5 of the
B&R gA Plan fov the
WNP-2 Project
B&R procedure
WNP-2-005,
WNP-2 Indoctrination and Training
Plan
B&R procedure
WNP-2-Pt4-013, Indoctrination and Training of
Project Personnel
Nine (9)
B&R Discipline Indoctrination
and Training Requirements
Matricies
Fifty five (55) personnel training records.
No items of noncompliance
were identified in this area of
the inspection.
(3)
Gilbert
Commonwealth Associates
The inspector
examined'the
following WPPSS
and (Gilbert) Commonwealth
Associates
(G/CA) training procedures,
identified training
requirements
and personnel
training records:
WNP-2 Project Instructions-Project
Indoctrinations
and
Training
Section
1.5 of the
G/CA gA Plan for the
WNP-2 Project
6/CA Engineering
Procedure
gAP 2.3, Indoctrination and Training
of Personnel
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G/CA Engineering
Procedure
DCP 5. 15, Indoctrination and Training
of Personnel
One (1) G/CA Training Plan/Schedule
Twenty-nine
(29) personnel
training records.
Ho items of noncompliance
were identified in this area of
the inspection.
Furthermore,
the inspector verified that:
(1) the education
and work experience
information contained
in employees'ob
applications
are being verified by the employing
organization;
and (2) there is objective,
documented
evidence
that attest to the education
and experience of both permanent
and contract
employees of (Gilbert) Commonwealth Associates
deployed
on the
WHP-2 site under contract no.
C-0208.
d.
Desi
n Verification
The
HRC Region IV Vendor Inspection
Branch conducted
an inspection
of the Burns and
Roe Corporate
Headquarters
during September
15-19,
1980.
The subject of independent
design verification was examined
and it was considered
unresolved
because
(1) the Burns
and
Roe
review of contractor design
documents is conducted to determine
conformance with design specifications,
not to verify the adequacy
of the contractor's
design;
and (2) it was not apparent that procedures
have
been established
and employed to assure that activities related
to design verification are carried out in a planned, controlled,
orderly and correct manner.
The WNP-2 PSAR, paragraph
D.2. 8. 3, states that, "In all cases,
prior to submittal to either
WPPSS or Burns and
Roe for review
and approval, the design contractors
including Burns and
Roe are
responsible for verifying the adequacy of design,
such
as
by the
performance of design review, by the use of alternate
or simplified
calculation methods, or by the performance of a suitable testing
program.
The verifying or checking process
shall
be performed
by individuals or groups other than those
who performed the original
design, but who may be from the
same organization. "
The WNP-2 FSAR, Appendix C. 3, specifies that
WNP-2 complies with the
guidance set forth in Revision 0 of Regulatory
Guide 1.64 entitled
"guality Assurance
Requirements
for the Design of Nuclear Power Plants. "
Rev.
0 endorses
ANSI N45.2. 11 (Draft No. 3,
Rev. 1-July, 1973) which states,
inter alia, that "The results
of design verification efforts shall
be clearly documented,
with
the identification of the verifier clearly indicated thereon";
"Documentation of results shall
be auditable against
the verification
methods identified by the responsible
design organization";
"Where
changes
to previously verified designs
have
been
made,
design verification
shall
be required for the changes,
including evaluation of the effects
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of those
changes
to the overall design";
"The responsible
design
organization shall identify and document the particular design
verification methods to be used";
and where the design review method
is used,
"Established
procedures
for design review shall
be followed,
the results of the review documented,
and measures
taken to ensure
that the findings are implemented."
The ANSI N45.2. 11 standard
also
specifies that, where the design review method is selected,
a number
of basic questions
should
be addressed
where applicable.
The inspector could not locate any evidence that a comprehensive
design verification program, defined and prescribed
by a procedure
incorporating the requirements
of ANSI N45.2. 11 is in place at MNP-2
with the exception of the small bore piping design verification
activities being performed
by (Gilbert) Commonwealth Associates.
The inspector
could not locate any evidence that the requirements
of ANSI N45.2. 11 or its equivalent
have
been
imposed
on contractors
performing design activities e.g. contract nos.
215, 216, 218 and
220.
This apparent oversight
was documented
by the licensee as-
item no.
1C in Corrective Action Request
No.
1486.
Project management
responded
to Corrective Action Request
No.
1486 by stating that
"For design
performed directly by the contractor,
included must
be adequate
design review/verification and the procedures
and qualified
personnel
to implement."
This response
was accepted
by the quality
assurance
organization
and
a letter was later issued to contractors
performing design activities which stated that
"An interpretation
that Burns
and
Roe performs review functions for contractor
design
scope is neither correct nor acceptable
to WPPSS."
The inspector discussed
this issue with project engineering
personnel.
The licensee
stated that the provisions of ANSI N45.2. 11 are being
met by the Burns and
Roe design control procedures
although
no
single comprehensive
design verification procedure is being used.
The licensee further stated that the requirements of design verification
are
imposed
on the contractors
performing design activities by
10 CFR 50; Appendix
B which is a contract requirement.
The licensee
committed to compare the requirements of ANSI N45.2. 11 against
the
Burns
and
Roe design control procedures
to indicate to the
NRC how
the provisions of ANSI N45.2, 11 are being satisfied.
The licensee
also committed to prepare
a checklist of ANSI N45. 2. 11 requirements,
to compare these
requirements
with the design verification requirements
of the contracts
and audit the contractors
against
any differences
to ascertain
the degree of compliance.
The issue of design verification
is considered
unresolved.
(50-397/81-03/02)
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Naintenance of Installed
E ui ment
The inspector
examined the
MBG Preventive
Maintenance
System
(PMS) for
conformance to ANSI N45.2.2 and applicable contract
and procedure
requirements.
The inspector also examined
equipment
placed in its final location within
the power plant to verify conformance to the above standards.
On February
19,
1981 the inspector
observed that the motor heaters for
standby service water
pump
1A were not energized.
This was verified
by a site electrician.
The inspector
reviewed the maintenance
history
of this
pump and was unable to establish
when, if ever, the motor space
heaters
had been energized.
A November 10,
1980 maintenance
report form was not issued or completed
by 'HBG.
Additionally, maintenance
reports
were not available for the
first or second quarters of 1980, although
MBG had accepted
custody
of this equipment
on December
14,
1979 from MPPSS startup.
The review of maintenance
documentation
also disclosed that the motor
had not been tested for insulation resistance
since August 7, 1979,
although the
lJBG planned maintenance
item data sheet,
prepared
in accordance
with MBG Permanent
Plant Equipment/Valve Maintenance,
Rework,
and Repair
Program
(Procedure
No. MP-106) required these tests quarterly.
The
lack of control of storage conditions
and incomplete
implementation of
maintenance
procedures
is an apparent
item of noncompliance
(50-397/
81-03/03).
Alle ation of Record Falsification
Review of ualit
Records
An allegation
had been
made that
HBG pipe and hanger quality records
were falsified (IE Inspection
Report
No. 50-397/80-08).
Approximately
50 of the photocopied
records
were compared with the original records
during the investigation conducted
June
3 - July 25,
1980.
During a
subsequent
inspection
performed
November 4-7,
1980 the inspector
examined
an additional
32 pipe quality records
(IE Inspection
Report
Ho. 50-397/
80-19).
While there were instances
where information on the records
had
been
added,
changed,
or deleted, in each
case
the correction
had
been initialed and dated
as required
by the contractor's
procedure
no.
MP-153, entitled
"Changes to guality Related
Records/Documentation".
The alleger met with the inspector
and reiterated
the allegation that
MBG quality records
were falsified.
The inspector
examined
an additional
213 quality class I pipe records
(Form NF-6 and NF-6A) for discrepancies
with the photocopied records.
The inspector identified the following discrepancies:
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a)
b)
Pipe Meld Record
No.
BCG-217
Meld Number B-36-1
The photocopied
record contains
a fit-up quality control hold point
that was not initialed and dated.
All other quality control hold points
were initialed and dated
between
August 28,
1978 and September
5, 1978.
On the original record, the fit up quality control hold point was
initialed and dated August 28,
1978.
No indication was
made
on the
original weld record that the fit up quality control hold point
was initialed after September
5,
1978 and back dated to August 28,
1978.
The inspector
met with the quality control inspector
who initialed
and dated the fit up quality control hold point and asked if he
recalled completing the weld record.
The inspector also exhibited
the
1979 photocopied weld record to the quality control inspector.
The quality control inspector
stated that he may have forgotten to
properly note on the weld record that the hold point was checked but not
initialed and dated
on the weld record until a later date.
The inspector
was
shown the Daily gC Work Report which indicated
the quality control inspector
who initialed the fit-up quality control
hold point in question did examine the pipe fit-up in August 1978.
Pipe
Weld Record
No. DE-062-1.19
Held Numbers 5-1, 9A,
15
The inspector found no discrepancies
between
the photocopied
quality records
and the originals stored at the
WBG vault, however,
the weld record packages
do contain discrepancies.
The weld filler metal-withdrawal slip (Form NF-69) contained in
the weld record package
does not always support the entries
made
on the weld record
(Form NF-6).
For example,
on weld number
15
the welders
name appearing
on the weld record is not the welders
name appearing
on the weld filler metal-withdrawal slip.
Other
discrepancies
noted were heat
numbers
and welding dates
appearing
on the weld record not corresponding
to heat
numbers
and withdrawal
dates
appearing
on the weld filler metal-withdrawal slip.
This
problem was discussed
during the exit meeting
and the licensee
committed
to review the weld record packages
and resolve the discrepancies.
The licensee's
action taken to resolve the discrepancies will be
reviewed during
a further inspection.
(50-397/81-03/04)
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8.
WPPSS Task Force II-Review of Contractor
Work Methods-Licensee
Action
n Res onse to
NRC 10 CFR 5
.
f
Reouest
'a ~
b.
General
The licensee
established
a task force
(Task Force II) to assure
that site contractors
are properly prepared to restart work and
to engage
in completed work reverification inspection/reviews.
Task force responsibilities
include review of contractor work methods
including procedures,
personnel
qualifications,
and training.
Areas
examined during this inspection include Contract
218 receiving
inspection activities
and task force team reverification package;
Contract
213A containment weld pad activities
and task force team
reverification package;
and interviews with former and current task
force team members
and management.
Contract 218-Fischbach
Lord-Receivin
Ins ection-Work Activities
an
roaram
ev>ew.
0
Although restart of'ischbach/Lord receiving inspection
was imminent,
it had not begun at the date of this inspection.
The inspector
reviewed Fischbach/Lord
procedures
CP/gAP 201, "Receiving, Handling,
Storage
and Issuance"
and CP/gAP 107, "Indoctrination, Training,
and Certification of Personnel" for compliance to ANSI N45.2.2 and
ANSI N45.2.6 respectively.
No items of noncompliance
or deviations
were identified.
The inspector
reviewed training records
and tests for Level I and
Level II receiving inspectors.
The inspector noted that written
tests
on receiving, storage,
and handling contained
no questions
directed to the specific requirements
of ANSI N45.2.2 (or CP/gAP
201) for receiving inspection or storage.
The written tests
seemed
to be directed at proper document control and contained only general
questions
as to where storage
requirements
were located.
The tests
lacked questions
on storage level categories,
typical equipment items
within these categories,
and specific storage conditions required
for each category.
Receiving inspectors
were interviewed
and generally
appeared
weak in their knowledge of these requirements.
The contractor's
quality assurance
manager stated that this issue would be reviewed
prior to restart.
The contractor's
storage facility for level
8 items and the cable
storage
area
(level
D) were inspected for compliance to industry
standards
and contractor instructions.
The level
8 warehouse
appeared
to meet these
requirements.
The cable storage
area in general
met
the storage
requirement but several
discrepancies
were noted.
Several
cables
were stored with ends not taped or capped to prevent
moisture entry, one cable reel
was partially covered
by dirt, and
one empty reel
was resting
on cable wound on other- reels.
These
items were addressed
to the contractor's guality Assurance
Manager
who stated that corrective action would be taken.
As these
examples
appeared
to be isolated
cases
the inspector
had no further questions
in this area.
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Contract 218-Fischbach
Lord-Receivin
Ins ection-Review of Task
rou
Reverification Packa
e
The licensee,
in response
to the NRC's
10,CFR 50.54(f) request regarding
quality assurance
dated
June
17,
1980, comitted to a reverification
program.
This program entailed establishing
a task force of five
teams to review the quality assurance
procedures of the various
contractors for completeness.
Reverification packages
prepared
by the task force teams
document their review and findings.
The reverification package for "Receiving Inspection",
Fischbach/
Lord-Contract 218 was reviewed
by the inspector to determine the
thoroughness
of the review.
The reverification effort was
a review of the
quality assurance
procedures
for the receiving of safety
related
components
and materials.
A number of recommended
revisions
to various receiving inspection
procedures
resulted
from this review.
An issue of concern that developed during the task force team's
review was the reclassification
from quality class II and III to quality
class
I of some
208 purchase
orders for electrical materials
and
hardware.
The contractor's
corrective action plan, in process
at
the time, was to review all purchase
orders pertaining to quality
related items.
This review, initially intended to include 208
purchase
orders, will now encompass
approximately
15,000 purchase
orders
and will be completed
by October 1,
1981.
No deficiencies
were identified during the inspector's
review of a few of the small
number of the initial 208 purchase
orders reverified to date.
.
d.
Contract 213A-Pittsbur
h Des Moines Steel
Inc.-Held Pads
Containment
1)
General
The inspector initiated an examination of the
"WNP-2 Reverification
Package for Weld Pads,
Containment".
The package is
a two
volume report 'which provides the results of a review, performed
by Team
P<2 of the
RCSW Task Force II, of the readiness
of
Pittsburgh
Des Moines Steel, Inc., to restart the safety related
work of containment weld pad installation.
The objectives of the Task Force review as defined
by WPPSS
correspondence
through the second
progress
report of December
1900 are to determine
the adequacy of procedures,
adequacy
of training and qualification, completeness
of document
packages
(quality records),
and the adequacy of recently completed
work.
The
second progress
report to the
NRC identified
that future packages
would not include
a review of recently
completed work but rather would increase
the scope of new
work surveillance,
however, the package
examined
on weld pads
did contain
a sampling review of recently completed work.
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The second
progress
report added
a committment to expand the
scope of activities to include an evaluation of the contractor's
management
systems
as
a prerequisite to restart.
The inspector observed that the licensee's
evaluation for
readiness
to restart work did not include
an assessment
of
the adequacy of the site engineering
forces which are an intrinsic
part of the performance of work.
The adequacy of engineering
was not specifically assessed
by the inspector,
however,
two items
in this section of this report paragraphs
8.d.6)
and 8.d.8)
indicate there
may be
a problem with (1) the amount of engineering
overview of the contractors
and (2) the quality of the engineering
rationale
used in resolving nonconformances.
The inspection
included interviews of the
Team 2 leader
and one member of the team who prepared
the report,
and the
personnel
involved in the review and approval of the report
and the release of the work.
The inspector
also interviewed
certain
PDM personnel
involved in the resolution of items
identified by the review and the control of new work; specifically
the
PDM Project Manager, guality Assurance
Manager
and
a
We'Id
Engineer.
The inspector also interviewed the
WPPSS project
quality assurance
personnel
involved with surveillance of the
new weld pad work.
Results of the interviews are included below.
2)
Licensee
Method of Packa
e Review
Through the interviews the inspector determined
the
MPPSS review
of the team's
product
(The reverification package)
was performed
in the following manner:
a)
The Deputy Project Manager,
Systems
Turnover briefly reviews
the package.
The Team Leader administratively reports
directly to the Deputy.
The Deputy forwards the package
to Project guality Assurance.
b)
Project guality Assurance
personnel
review the package
by a less
than
1008 audit technique.
Project guality
Assurance
used
a checklist to record what was
sampled
and
a cottmnt sheet to record problems identified.
About
10 man-days
were required for this review.
c)
The WHP-2 guality Assurance
Manager provides
a letter
to the Program Director identifying constraints
to restart
and items which are not considered
a constraint to restart
but require timely completion.
d)
The program director directs restart through Construction
Management.
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3)
4)
e)
Construction
Management
personnel
track open comnittments
identified by the Project guality Assurance letter.
f)
Project guality Assurance
surveillance
personnel
audit work
activities.
The inspector observed
that, the format of the report did not
provide for a concise explanation of the types of problems
identified in the review and the corresponding
corrective
actions, therefore
an overview of the adequacy of the actions
taken
was not possible.
At the exit interview licensee
management
stated that future packages
would identify the types of problems
and the corresponding
corrective actions.
At the request
of the Project guality Assurance
Manager,
the Deputy Project
Manager for Systems
Turnover issued
a memorandum
dated
March
9,
1981 implementing
a requirement for a summary of problems
and solutions in future task force packages.
These
summaries
will be reviewed in the normal
course of future inspections.
Status of Mork
Through discussion with site personnel it was determined that
four weeks of work was to be identified in the initial work
release,
in this case
40 weld pads.
Subsequent
to work release,
engineering withdrew 33 of the weld pads for redesign
and
4 required the assembly of documentation
packages,
only leaving
3 workable weld pads.
When queried,
licensee
management
personnel
stated that they were not aware of this situation.
Ade uac
of Procedures
The inspector
examined the report section dealing with procedure
review.
As a result of the licensee
stopwork order, basically
all the contractor procedures
had been or were being revised
by the contractor concurrent with the team review.
The procedure
review checklists
used
by the team for welding and nondestructive
examination
were examined
and were found to be detailed
and
comprehensive.
The inspector
examined the team's
procedure
review comment
sheets
and selected
23 comments
and contractor resolutions
for detailed review.
In general,
the
comments
were adequately
resolved.
However, the following problems were noted:
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a)
In 3 of the 23 cases
the task force team accepted
a contractor
response
which promised action (e.g.
"a Project Engineering
Directive will be issued").
The corrments
were signed
off as completed
on the team review sheets
without followup
that the action was taken
and without transfer of the
item to any other committment tracking system.
The inspector
followed up on the items
and determined that the actions
had in fact been taken.
0
At the exit interview of February 27,
1981 licensee
management
comitted to issue
an instruction letter to the task force
members to prevent recurrence of this situation.
This
was accomplished
on February 26,
1981 by a memorandum
'rom the Deputy Project Manager for Systems
Turnover to
the team leaders.
This item will be inspected
in the
normal course of future package
examinations.
b)
One of the review items, (checklist
RICS Rev. 4, Item
C.8). requires
review of the procedure for NCR, RFI,
(i.e. vehicles for reporting nonconforming conditions).
The item was signed off as
"N/A" by the team on the basis
that the procedures for NCR, RFI and
CAR are covered
in the .contract specifications.
As explained to the
inspector
by the team leader,
the contract specifications
contain general
requirements
imposed
by NPPSS project-
wide but are not implementing procedures.
The implementation
by
PDM is done in the guality Assurance
Manual.
The Project guality Assurance
Personnel
reviewing the
team package
made
a comment
(comment
83 on Project guality
Assurance
review sheet
page
2 of 3) stating basically
that the contractor's
in-house procedures
should
be reviewed.
The team responded that. the in-house
procedures
(the
gA manual) were covered in Section
G of the package.
This response
was accepted
by the Project guality Assurance
personnel
and the item was closed.
Section
G of the packaqe
has
a guality Assurance
Program
Checklist
(b'213A G.2(a)-01).
Item 15 of that checklist
deals with characteristics
of the contractor's
guality
Assurance
program to be checked for nonconforming materials
but is signed off as "not reviewed" by the team leader.
The inspector reviewed the
PDM procedure for reporting nonconforming
conditions.
The procedure is contained in the
PDM guality
Assurance
Manual Section
12.
The inspector reviewed the procedure
against the guidance
given in NUREG 75/094,
NUREG 75/087,
Regulatory
Guide
1. 58 with ANSI N45.2,
and Regulatory
Guide
1. 123 with ANSI N45.2. 13.
The inspector noted the following
apparent
deficiencies in the
PDM procedure:
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a)
The authority and method for the quality control inspector
to stop work is not delineated.
b)
The necessity
to provide justification for a "use-as-is"
resolution is not delineated for Corrective Action Requests
(CARS).
c)
Storage of permanent plant records is not specified or
invoked.
d)
Responsibility to review reports for
applicability is not specified.
e)
The cause of the nonconforming condition is not required
to be recorded.
f)
Controls on voiding of corrective
action requests
are
not specified.
It was noted that the lack of voiding
policy in the procedure
was recognized
and
a
PDN memorandum
dated 3-4-81 was issued to all
PDfl personnel
on the subject
of voiding policy.
The
PDM policy memorandum
was
a result
of a
HPPSS Project Quality Assurance Letter to the Deputy
Project Yianager,
Systems
Turnover of February 3,
1981
wherein the task forces were requested
to assure that
contractor procedures for nonconformances
properly addressed
the issue of voiding.
It appears
that the adequacy of the contractors
nonconformance
procedures
has not been adequately
assessed.
It further appears
that the problem was not proper'ly followed up, by virtue of
the fact that the inadequacy of the contractors
nonconformance
procedure did not appear
as
an action item (constraint or concern)
on the Project Ouality Assurance
release letter, nor was the
action to upgrade the contractors
nonconformance
procedure
identified on any other licensee tracking system.
The licensee action to review the
PDN nonconformance
procedure
will be inspected in a future inspection.
(Item 50-397/81-03/05)
5)
~Tnainin
The inspector interviewed Project guality Assurance surveillance
personnel
who had audited the
PDM training sessions.
The
guality Assurance
Engineer appeared
familiar with the revised
PDM training procedures
and
had attended
several training
sessions
in an audit capacity.
The inspector
reviewed the training section of the Task Force
team package,
including a sample of team cotrments
and resolutions.
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The items identified by the team as not yet done at the time
of package
issuance
were:
a)
establish
a matrix of training requirements
for all jobs
b)
formal training sessions
c)
issuance of a new training procedure
The Project guality Assurance
release letter only identified
that training sessions
and qualification were not completed.
The release letter did not identify that the training procedure
and matrix were required.
The problem summaries
committed
to by the licensee
(described in paragraph
8.d.2) of this report)
should assist in controlling these
types of "lost" action items.
The inspector interviewed the
PDN training staff and discussed
the organization
of the training, the subject matter, covered
and the status of implementation of written examinations.
The
organization
and administration of training as it was being
practiced
and the dedication to quality training of the training
personnel
appeared
to be satisfactory.
The inspector
noted
that the methods of administering training, i .e. matrices
and
record keeping systems,
were not described
by procedure in
order to maintain flexibility (per the trainers).
The
training personnel
were not permanent
PDN employees.
Therefore,
although the future training bears attention, the current
training was considered well controlled and >tell executed.
Observation of Work
The inspector
examined
some of the work in progress,
completed
work and work areas for the weld pad installation.
The work
was reviewed against
ASNE Section III Subsection
HE and
PDN
procedure
requirements.
Specifically the inspector
examined
the following areas:
a)
Weld rod issue station - Weld rod issue practices
and
storage
temperatures
were in accordance
with procedure
FNC-1.
b)
Installation of Weld Pad
178-2 - 7he inspector verified
the final weld size
and appearance
and observed
the quality
control inspector perform the final visual
and magnetic
particle examination.
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c)
d)
e)
The inspector
interviewed the
gC inspector,
the mechanic,
the responsible
foreman
and the general
foreman
and observed
the use of the sequence
and signoff document (Field Checklist-
FCL).
The control of the work and the use
and signoff
of the
FCL appeared
well understood
and executed.
The inspector questioned
the methods of fitup of the
flat plate weld pads to the curved containment wall.
The method
used is to weld temporary attachments
(dogs)
to the containment wall for forcing the plates to the
wall to achieve fitup gap.
The inspector further questioned
whether that method of fitup had
been evaluated
by engineering.
The Burns
and
Roe civil engineering
personnel
stated
they were not aware of the method of fitup and were concerned.
The engineering evaluation of the method of fitup of
weld pads will be inspected in a future inspection.
( Itern 50-397/81-03/06)
Completed weld pads - The inspector examined
completed
weld pads
180-9,
167-13,
and 189-13.
Visual weld quality
and weld size were satisfactory.
Weld pad material
was
properly identified by marking.
Weld pad prefabrication
area - The inspector
examined
work in the prefabrication
area including repair of plate
edge indications
on weld pad 187-15.
As permitted
by
the
ASME code for material repairs,
the code limitations
on depth of repair
had
been
extended in the contract
specifications
by project engineering directive.
Plate
laydown area - The inspector
examined the plate
laydown area
and interviewed the quality control inspector
in charge of the area.
The area
appeared
orderly and
the inspector
seemed
knowledgeable
regarding the requirements
for material control and traceability.
No items of noncompliance or deviations
were observed
in the
above work areas.
7)
Review of ualit
Records
The inspector
examined the following quality records:
a)
b)
gualification and training records for one welder.
Nondestructive
examination qualifications for two examiners;
It was noted that
MPPSS/PDN
does not require certification
of guality Control qualification for guality Control inspectors
in accordance
with a proposed revision to the Safety
Analysis Report.
They do require certification
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of experience
and do require training prior to work assignment.
The inspector verified the work experience certification
and training of two quality control inspectors.
c)
Peceiving records
and material certifications for two
lots of weld rod.
d)
Receiving records
and material certifications for two
heats of plate material.
The inspector identified a
discrepancy in the traceability of the plate manufacturer's
and the correspondingly identified material
certifications, to the
PDM assigned
material control number.
The problem was
due to a typographical error on the
document
check list.
The document
check list is supposed
to provide the correlation
between
the
PDH control
number
and the manufacturers
In the instance
observed,
the
same
PDM number was entered twice for two heat numbers.
The situation was corrected
by contacting the
PEN home
office and correcting the site records accordingly.
The
inspector reviewed other material
records
and determined
the error was apparently
an isolated incident.
In all the above records
review,
no items of noncompliance
or
deviations
were identified.
8)
Oualit
of En ineerin
Dis ositions
As stated in the introduction to this section of the report,
paragraph
8.D. 1, the task force was not chartered with the
responsibility to review the quality of engineering dispositions
as it related to restart of work by PDth.
The inspector in reviewing the restart
package
noted that the
task force had no cogent
on nonconformance
report
NCR 213A-
06524.
The
NCR dealt with weld electrodes
not baked at the
proper temperature prior to use.
The disposition provided
by Burns and
Roe engineering stated
"accept
as is, final NT results
(performed
same
day as welding) are satisfactory".
In the
opinion of the inspector the answer
was inadequate.
Loss of
moisture control in weld rod would potentially result in hydrogen
induced underbead
cracking
.
Underbead
cracking is best detected
by volumetric examination not a surface
examination
such
as
magnetic particle examination
(HT) and since
underbead
cracking
is
a delayed
phenomenon,
examination is usually done
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
after welding, not the
same day.
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The inspector investigated further
and satisfied himself that
a technical
concern for underbead
cracking did not exist.
The
f'ICR wa~ written because
the weld rod was not first baked
at 750-850
F as required
bg the
The
weld rod was stored at 250 -350 F.
The American Welding Society
only requires
storage at at least
250
F for previously hermetically
sealed
SFA 5. 1 weld rod.
At the exit interview of Narch 13,
1981 the inspector
discussed
the restart review he had performed and voiced
a reservation
concerning the quality of engineering dispositions
since that
aspect of restarted
work had not been evaluated.
The licensee
management
coomitted to provide the rationale
for not reviewing the technical
adequacy of contractor
and
Burns
and
Roe engineering resolutions
as part of the evaluation
for restart of quality related work.
Subsequent
to the inspection,
the rationale
was provided to the resident inspector
and then
related to the inspector.
The licensee rationale
was that
WPPSS project engineering
has previously audited
Burns
and
Roe engineering
from a technical standpoint,
and that all
PED's (project engineering directives) specification
changes
are sent to
WPPSS for information and certain types of PED's
(major changes)
are approved
by WPPSS engineering.
The licensee
intends to fulfilltheir committment to review
the quality of dispositions
during the phase II review.
The
licensee
also pointed out that although not directly related
to evaluating the engineering quality of dispositions,
other
engineering
considerations
were assessed
for restart.
These
actions
appeared
to be primarily administrative
such
as backlog
reviews
and reviews of engineering
paper processing
problems
such
as those described in Burns
and
Roe Corrective Action
Request
(CAR) No.
1486.
The inspectors
concluded that, since they had not identified
any improper engineering resolutions
in the review of restarted
work, there was
no basis to require
an immediate licensee
review of engineering
adequacy.
When the licensee
does fulfill
the committment to review the quality of engineering dispositions,
any problems identified would have to be reviewed
by the licensee
for applicability to the
new work currently being performed.
The quality of engineering dispositions will be examined further
in the normal
course of future inspections.
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9)
~Su<<<a<
The inspector concluded, after a two week evaluation of-PDN's
restarted quality related work that weld pad installation
was
adequately
controlled and performed in a manner which was
resulting in a quality product.
As expressed
at the exit interview
of March 13,
1981 the inspector
had reservations
regarding
quality of engineering dispositions,
an area which had not
been evaluated
by MPPSS for restart.
Additionally, the inspector
pointed out that since the
PDM >corkload at the time of inspection
was very low, the continued control of work should
be further
assessed
when the workload was increased
to normal levels.
Interviews with Task Force II Members
The inspectors
interviewed, individually, 21 former and current
task force II members,
including members
from each task force team.
The interviews were conducted
by using
a standard checklist which
was structured to determine
the freedom of the task force members
to identify quality concerns
and to bring the appropriate
management
attention to bear to resolve the concerns.
The interviewees
included
members of the task force teams for contract nos.
213A, 215, 216,
217, 218, 219,
220 and 234.
Among the interviewees
were
16 contract,
2 Bechtel,
1 Burns
and
Roe and
2 HPPSS personnel.
The interviews indicated that
16 of the individuals felt that they
were encouraged
by management
to raise issues
and seek resolution
of those issues.
Concerns
regarding quality problems
were generally
documented
by task force members
on interoffice memorandums.
Sixteen
of the task force members
have prepared
memos addressing
quality
concerns
of which 14 were personally satisfied with the action taken
to address their concerns.
Seventeen
interviewees
indicated that
management
has
never told them not to document
a quality concern.
Three individuals felt that they were instructed not to document
quality concerns.
The inspectors
met with the Deputy Project Manager
for Systems
Turnover who had initiated a meeting which resulted
in this misunderstanding.
The Deputy Project Manager later met
with these individuals and issued
a memorandum to all task force
members
emphasizing that channels of communication
are
open but that
verbal discussions will sometimes
resolve apparent
concerns
more
expediently.
The memorandum stated that where the individual feels
it necessary
to write a memorandum,
he should not hesitate
to do
so.
The inspectors
met again with the interviewees
who then felt
satisfied that they were free to document quality concerns.
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Ten task force members
expressed
concern that reinspections
of
selected
components
were not being performed in light of the deficiencies
identified during the software reviews
and procedure
and program
revisions.
These
concerns
were expressed
to the licensee
by the
NRC inspectors.
The mechanisms
used to factor the deficiencies
identified during the restart efforts into the actual reverification
process
(Task II Phase II) will be examined
when the reverification
process is defined.
The resolution of specific areas of concern
that have
been
documented
by the Task Force
members will be examined
during subsequent
inspections.
9.
Wana ement Interviews
The inspectors
met with the licensee
representatives
denoted in paragraph
1 at the conclusion of each inspection period.
The items inspected
and the observations
and findings of the inspectors
were discussed.
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