ML17276B379

Submits Revised Response to NRC 800121 Ltr Re Violations Noted in IE Insp Repts 50-397/79-10 & 50-397/80-08. Corrective Actions:Piping post-weld Heat Treatment Will Follow Bechtel Procedures

ML17276B379
Person / Time
Site:	Columbia
Issue date:	03/11/1982
From:	Matlock R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17276B378	List: ML17276B379
References
GO2-82-319, NUDOCS 8204070547
Download: ML17276B379 (16)

Text

Washington Public Power Supply System P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 Docket No. 50-397 March ll, 602-82-319 1982 Mr. R. H. Engelken U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 260 Walnut Creek, California 94596

Subject:

NUCLEAR PROJECT NO. 2 - CPPR-93 REVISED RESPONSES TO NRC NOTICE OF VIOLATIONS 79-10/01, 79-10/03, 80-08/09, AND 80-08/22

References:

a) 602-80-120, dated June 11, 1980 b) 602-80-209, dated September 19, 1980 Reference a) transmitted the Supply System's response to Notice of Violation 79-10/01 and 79-10/03. Reference b) transmitted the Supply System's response to 80-08/09 and 80-08/22. Subsequent to the transmittal of these replies, organizational and procedure changes at WNP-2 have occurred which require submittal of revised responses for these four (4) violations. The Supply System committed to provide these responses in NRC Inspection Report 81-22. Attachments 1 through 3 fulfill that commitment in part. The response to 80-08/22 is not included in this letter, but will be provided prior to March 19, 1982.

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Program Director, WNP-2 RTJ/kd Attachments: (3) As stated cc: W.S. Chin, BPA - Site R.A. Feil, NRC Resident Inspector - Site A. Forrest, Burns and Roe - HAPO N.D. Lewis, NRC J. Plunkett, NRC R.E. Snaith, Burns and Roe, NY V. Stello, NRC RMSF 917Y 820331 j 8204070547 05000397

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ATTACHMENT 1 Notice of Violation in letter from G. S. Spencer to N. 0. Strand dated January 21, 1980 (GI2-80-17).

t Appendix A, Item A (79-10/01)

Notice of Violation: 10CFR50, Appendix B, Criterion IX, states,'n part, that "measures shall be established to assure ~

that special processes, including...heat treating..'.are controlled and accomplished by...using qualified procedures..."

J Paragraph D.2.5.9 of the Supply System equality 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. 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 lf 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 and Roe Isometric Drawing No. RFW-419-4.

This is an infraction.

Summary Due to Bechtel Power Corporation assuming Contract 215 (WBG) system completion work and associated procedure changes, revise our response.

it is necessary to Action to Correct Deficiency Old Response: A one dimensional transient analysis was performed*to determine the maximum temperature the feedwater piping reached, utilizing electrical resistance heater blankets specified in Post Weld Heat Treating Procedure No. PWHT-l, Revision 4.

Because the transient analysis results disclosed that the maximum temperature obtained anywhere on the pipe was below 1330 F, we concluded that the material adjacent to the weld and under the heating blanket, was not excessively over heated and that post weld heat treatment performed did adequately stress relieve the welds as desired. It is further noted that the analysis corroborates the findings of Report No. IT-119, dated September 28, 1979; titled "Results of Hardness Testing and Metallurgical Examination on Feedwater Pipe Welds at Washington Nuclear Project No. 2."

Y Page Two Action to Correct Deficiency (Continued)

New Response: It has been determined that fifteen ( 15) Code Class 1 welds in the RFW system and five (5) Code Class 2 welds in the MS systems were post weld heat treated using procedure PWHT-l. A metallurgical nondestructive examination was performed on weld 1Rl of piping isometric RFW 418-5.6.

This weld was chosen as the potential worst case of ASME Code Class 1 welds in question. As a vertical piping run, the weld would have been subject to a chimney effect with respect to air flow and, although within Code allowable limits, this Class 1 weld achieved the highest temperature on the strip chart recorder used in the PWHT process.

Hicrostructure, grain size and hardness analyses were performed on the base material on the area directly under the initial heater blanket placement and also on a reference area approximately six (6) feet from the weld area. The results of these examinations provide justi-fication that adverse metallurgical properties have not been induced near the subject welds by the use of PWHT-1.

A full report of this analysis has been generated and is available for review.

Action to Prevent Recurrence Old Response: None stated.

New Response: WBG assumed direct responsibility for all PWHT upon termination of the PWHT subcontractor's contract. WBG's procedure provided for in-line review and approval of PWHT procedures. PWHT will now be accomplished in accordance with proven Bechtel procedures.

Date of Full Compliance Old Response: None stated.

New Response: WBG assumed responsibi lity for PWHT effective September 12, 1979 in accordance with approved procedures.

Bechtel assumed responsibility for PWHT effective September 3, 1981, in accordance with approved procedures.

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ATTACHMENT 2 Notice of. Violation in letter from G. S. Spencer to N. 0. Strand dated January 21, 1980 (GI2-80-17).

Apen 'ix A, Item C (79 10/03),

Notice of 'Violation: G01-80-55, D. L. Renberger to G. S.

Spencer (3-5-80). 10CFR50, Appendix B, Criterion XVII, states, in part, that "sufficient records shall be maintained to furnish evidence of activities affecting .

quality..."

Contrary to the above, on May 31, 1979, it was found that sufficient records shall be maintained to furnish evidence .

of satisfactory heat treating of safety related pipe welding.

For example, several heat treated record charts were

,illegible (e.g. welds 6, 7, and 8 of BRI 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 BRI Isometric Drawing RFW-419-5.7); no had been recorded on heat treating data records oper'ators'ames (e.g. welds 6, 7 and 8 of BRI Isometric Drawing RFW-419-4, welds lA, 2, and 3 of Isometric Drawing No. RFW-419-5.7);

different and conflicting thermocouple numbers had been recorded for the heat treatment of the same weld (e.g.

the recorder charts and certification sheets for weld 8 of BRI Isometric Drawing RFW-418-4, weld 1 of Isometric RFW-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 BRI Isometric RFW-418-4, welds 1, 1A, 2 of Isometric RFW-418-5.6).

This is a deficiency.

Summary E

Due to Bechtel Power Corporation assuming Contract 215 (WBG) system completion work and associated procedure changes, to revise our response.

it is necessary Action to Correct Deficiency Old Response: 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

()uality Engineer who eval,uates the findings. Inspection Reports ( IR's) are initiated as necessary to obtain resolution of the discrepancies found.

New Response: WBG has reviewed all completed post weld heat treat (PWHT) charts and records for the PWHT conducted by Seattle Industrial. The thoroughness and adequacy of thi s review was documented in WBG Corrective Action Report gl53 and subsequent status reports. Inspection Reports ( IR's) and Nonconconformance Reports (NCR's) were initiated to obtai n resolution of discrepancies found.

Page Two Action to Correct Deficiency New Response: (Continued)

The NOR's (53) documented PWHT discrepancies such as:

o Temperature above or below the required range .

~ Temperature rise rate too high o Inadequate number or location of thermocouples o Inadequate soak time o Missing or incomplete records o Record anomalies Disposition:oF these di screpancies on the NCR's include:

~ Re-PWHT o Reirispection, including UT and RT o Hardness testi ng o Rejection, redesign, and refabrication'ction to Prevent Recurrence Old Response: As noted in B above, WBG has assumed direct responsibility for the PWN operation and has initiated a program to assure compliance to the revised PWHT procedure.

New Response: WBG assumed direct responsibility for all PWHT upon of 'the PWHT subcontractor's contract; 'ermination WBG's procedures provided for in-line ()A review of the completed PWHT records. PWHT wi 11 now be accomplished in accord with Bechtel procedures.

Date of Full Com liance Old Response: The review of all records initiated by Seattle Industrial and the initiation of IR's for discrepant conditions is estimated to be complete by April 1, 1980.

New Response: Review of records and documentation of discrepancies has been completed. All NCR's have been prepared and dispositioned.

All NCR's. have been closed (required action done and verified) except for four (4), which require PWHT to be re-done.

This re-PWHT will be performed by Bechtel as dictated by .

system completion and turnover activities.

ATTACHMENT 3 Notice. of Violation in letter from R. H. Engelken to R. L.,Ferguson, dated August 15, 1980.

Appendix A, Item D.3 (80-08/09)

Notice .of Violation: WBG ()uality Assurance Manual, Section 10 paragraph 10.3. I states, in part, that "all welling incl'uding tack welding is performed by welders qualified as required by Section III and Section IX of the ASME Code." ASME Section III, paragraphs NX-4321(b) and NX-4321.2 reqUire the welders of temporary attachments and tack welds to be qualified and that the material used for temporary attach-ments be compatible for welding to the component material and be certified. WBG Work Procedure No. 42, paragraph 20 requires, with respect to "Welder Record," a record of welder's name(s), filler metal used (includes heat and lot

':numbers as .applicable) and the date(s) that welding was performed."

Contrary to the above requirements, the weld record packages did not contain identification of welders or filler metals used for tack welds and temporary attachments made on pipe spools LPC-756-5.6, LPCS-756-19.21, and LPCS-2271-1.

This is an infraction.

Summary Due to Bechtel Power Corporation assuming Contract 215 (WBG) system completion work and associated procedure changes, it is necessary to revise our response.

Actions to'Correct Deficiency Old Response: The date and locations of all temporary attachments, welder and weld filler metal identification are recorded on Form NF-286. A review of all work packages requiring traceabi lity will be conducted to determine when the NF-286 form is required. Copies of the required NF-286 forms will be incorporated into the work packages. IR's will be issued when NF-286 forms are required but not located. Inspection reports have been written on the weld record packages for pipe spools LPCS-756-5.6, LPCS-756-19.21, and LPCS-2271-1.

New Response: Same as above.

Action to Prevent Recurrence Old Response: Work Procedure No. 42 has been revised and now provides for recording the welder identification, weld process, and identification of the filler material for temporary attachments and tack welds on the work package >veld=

material.

Page Two Action to Prevent Recurrence (Continued)

New Response: Work Procedure 42 has been revised and is now.incorpor-ated into GWS-l, .Revision 3 (General Welding Standard, Repair Welding and NDE to Structural Steel), and GWS-2, Revision 3 (General Welding Standard for Welding, Repair Welding, and NDE requirements to Piping, Components and, Supports). These standards clearly provide for the recording-of all pertinent information for temporary attachment welding in Sections 4.2.8 and 4.2.2 respectively.

WBG will perform the review of documentation for the hardware they installed and identify any NDE reports not

,traceable to a specific welding activity. Bechtel will

'alkdown the'appropriate hardware to determine if there is a related blended or rough area that is indicative of removal of a temporary attachment. Those cases where the document review, together with the hardware walkdown, indicates that a temporary attachment was made without proper documentation will be documented on a NCR.

Date of Full Compliance Old Response: January 1, 1981 New Response: February 19, 1982

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Date ROUTING AND TRANSMITTAL SLIP TO: (Name, office symbol, room number, Initials Date building, Agency/Post) r~tr- + Ctg('v 4.

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ctlon File Note and Return pproval For Clearance Per Conversation Requested For Correction Prepare Reply irculate For Your Information See Me omment Investigate 'ignature Coordination Justify REMARKS Attached is. the original copy of a "Thank Youn letter sent to you and Washington Public Power, P. 0. Box 1223, Elma, WA 98/41.*

This corrected -copy has the right Dock'et Number, Address, and Attention line.

DO NOT use this form as a RECORD of approvals, concurrences, disposals, clearances, and similar actions FROM: (Name, org. symbol, Agency/Post) oom No.Bldg.

5 2 8~ Phon No.

s->EIH-OPBONAL FORM 41 (Rev. 7-tr6)

Preecrlbed by GSA

• U. s. oovernment Prlntlne ottleer t97$ 2$ 1.tee/$ FPMR (41 CFlg 101-lle206 I

JAN 15 1982 IP@~Z[@PPPgj Docket No. 50-397

( RECQQ'Pg Washington Public Power Supply System 9 Jll> 28 19gp~ -12 P. 0. Box 968 V Richland, Washington 99352 NQHg gggg~ @

TIDC Attention: t1r. R. G. Hatlock Program Director, WNP-2 Project Gentlemen:

Subject:

NRC Inspection at Washington Nuclear Project No. 2 (WNP-2)

This refers to the inspection conducted by Nr. J. 0. Elin of this office.

on November 2-5 and November 16-20, 1981 of activities authorized by NRC No. CPPR-93, and to the discussion of his findings held by Nr. Elin with yourself and other members of your staff at the conclusion of the inspection.

Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

No =i.tems of noncompliance with NRC requirements were identified within the scope 'of--this inspection.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter.

f Such application must be consistent with the requirements of 2.790 (b)(1).

lEOt OFFICE/ RV/jk. ~ ~ ~~ ~ ~ ~

SURNAME/ EL IN ....DS .. FAULKENBERR/

DATE P

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'NRC FORM,318<10/80) NRCM

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0 JAN 15 '58K Should you have any questions concerning this inspection, we will.

be glad to discuss them with you.

Sincerely, B. H. Faulkenberry, Chief Reactor Construction Projects Branch

Enclosure:

IE Inspection Report No. 50-397/91-22 cc w/o enclosure:

R. B. Glasscock, guality Assurance Director ll. C. Bibb, Project Manager, MNP-2 Project G. C. Sorensen, MPPSS bcc: DMB/Document Control Desk (RIDS)

Distributed by RV:

State of llA (Lewis)

Resident Inspector (8)

Engelken (ltr)

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