ML17276B748

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SALP Rept for Jul 1981-Jul 1982.Weaknesses Noted:Design & Installation of Electrical Sys & Implementation of Corrective Actions in Const Deficiency Repts
ML17276B748
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Site: Columbia Energy Northwest icon.png
Issue date: 12/10/1982
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
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ML17276B747 List:
References
NUDOCS 8212170091
Download: ML17276B748 (42)


Text

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NUCLEAR REGULATORY COMMISSION REGION V

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE llASHINGTON PUBLIC PO!lER SUPPLY SYSTEM

'IJASHINGTON NUCLEAR PROJECT NO.

2 (LlNP-2}

FOR THE PERIOD JULY 1, 1981 THROUGH JULY 31, 1982 ASSESSMENT CONDUCTED SEPTEMBER 20, 1982 82i2i70091 8212i0 PDR ADQCK 05000397 6

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TABLE OF CONTENTS I.

INTRODUCTION II.

SUMMARY

OF RESULTS III. CRITERIA IV PERFORMANCE ANALYSIS 1.

Soils 8 Foundations 2.

Containment and other Safety Related Structures 3.

Piping Systems and Supports 4.

Safety Related Components 5.

Electrical Power Supply and Distribution 6.

Instrumentation and Control Systems 7.

Licensing Activities 8.

Design Control 9.

Radiological controls 10.

guality Assurance 11.

Reverification Program 12.

Plant Operations, Maintenance, and Surveillance 13.

Corrective Actions V.

14.

Implementation of Corrective Actions to Reported Construction Deficiencies SUPPORTING DATA AND SUMMARIES Table 1.

Construction'eficiency Reports (CDRs)

Table 2.

Investigation Activities Table,3; Enforcement Actions Table'4.

Inspection Pours Summary

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INTRODUCTION a.

Pur ose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations of the licensee's activities on an annual basis and evaulate the licensee's performance based on those observations with the objective of improving both the NRC Regulatory Program and the licensee's performance.

The assessment period for this report is July 1, 1981 through July 31, 1982.

The prior assessment period was May 1, 1980 through June 30, 1981.

Significant findings from the prior assessment are included in the applicable Performance Analysis (Section IV) functional areas.

Evaluation criteria used during this ass'essment are discussed in Section III.

Each criterion was applied using the "Attributes for Assessment of Licensee Performance",

contained in NRC Manual Chapter 0516.

b.

SALP Board Meetin A Systematic Assessment of Licensee Performanace (SALP) Hoard meeting was held in NRC Region V offices on September 20, 1982.

The Board Members were:

(1)

D. Sternberg, Chief, Reactor Projects Branch No. 1, RV.

(2)

R. Dodds, Chief, Reactor Projects Section 1,

RV.

(3)

R. Auluck, Project Manager, NRR.

(4)

A. Toth, Senior Resident Inspector, WNP-2.

(5)

,D. Feil, Senior Resident Inspector, WNP-2.

(6)

J. Elin, Project Inspector, Construction, WNP-2.

'(7)

A. D'Angelo, Reactor Inspector, Construction, WNP-2, RV.

(8)

D. Willett, Project Inspector, Operations, WNP-2, RV.

(9)

G. Yuhas, Radiation Specialist, RV.

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II.

SUMMARY

OF RESULTS Functional Areas I

Category 1

2 3

1.

Soils and Foundations 2.

Containment and Safety Structures 3.

Pipihg Systems 4.

Safety Related Components 5 Supporting Systems 5.

Electrical Systems 6.

Instrumentation and Control 7.

Licensing Activities 8.

Design Control 9.

Radiological Controls 10.

guality Assurance 11.

Reverification Program 12.

Plant Operations 13.

Corrective Actions 14.

Resolution of Construction Deficiencies X

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I II. CRITERIA The following evaluation criteria were applied to each functional area discussed in the performance analysis (Section IV);

1.

Management involvement in assuring quality.

2.

Approach to resolution of technical issues from a safety standpoint.

3.

Responsiveness to NRC initiatives.

4.

Enforcement history.

5.

Reporting and analysis of reportable events.

6.

Staffing (including management).

.1 7.

Training effectiveness and qualification';

'p 11 To provide consistent evaluation of lice'nsee performance, attributes associated with each criterion and describing the characteristics applicable to Category 1, 2, and 3 performance were, applied as discussed in NRC Manual Chapter 0516, Part II and Table'l.

The SALP Board conclusions were categorized as follows:

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Ll management attention and involvement are agressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety is being achieved.

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Ll management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety is being achieved.

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Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear strained or not effectively used such that minimally satisfactory performance with respect to operational safety is being achieved.

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IV.

PERFORMAMCE ANALYSIS The following is the board assessment of the licensee's performance in each of the functional areas and the boards conclusions and recommendations with respect to implementation of the Regulatory Program.

1.,

Soils an Foundations a

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~Ana1 sis The licensee, during the previous assessement period, identified problems in the area of soil compaction from an analysis of soil test data.

This was reported as a construction deficiency report.

The licensee addressed the technical issues raised by the deficiency and submitted a report to NRR detailing an acceptable resolution.

Region V inspection confirmed that corrective actions detailed in the licensee's report were implemented.

b.

Conclusion c ~

Category 2.

Board Recommendations i

None 2.

Containment and other Safet Related =Structures ui 'n t

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~Anal sis

'uring the previous appraisal period a lack of thoroughness was identified in licensee's response to NRC concerns over the sacrificial shield wall.

These specific issues have been addressed.

However, the licensee's disposition of recent observations that welds attaching pip'e whip restraints were not adequately evaluated and corrected did not recognize the specific NRC position regarding compliance with AWS

'wel.ding criteria; nor did it acknowledge existing questions on the

','alidity of the contractor's welding inspections.

The program for repair of skin plate welds in the sacrificial shield wall is 'being satisfactorily accomplished in conformance with the

'licensee's commitments to the NRC.

The investigation of an allegation in this area was not substantiated.

b.

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Conclusion Category 2.

Board Recommendation None.

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Pi in S stems and Su orts a ~

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( all A major qual,ity assurance program breakdown was indentified during the earlyp'art" of the prior appraisal period.

This included. design,'s-built documentation, minimum pipe wall

'hickness, andlsway brace assembly adequacy questions.

The

'pecificnd general matters have bee'n or are being addressed

,by the, licensee, but were not completed by the end of this

,'appp'aisal;period.",Progress toward resolution of the issues has been noted"and constitutes improvement in this area.

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,', During 'the curKrent appraisal period the licensee'limited the

'echanical contr'actor work scope to identification and resolution

', 'f;discrepancies in documentation of prior work.

New piping and.pipe hanger work, was assumed by Bechtel.

This permitted the contractor to focus total resources on an intensive quality assurance effort relating to materials acceptability and

,'nstallation adequacy.

This effort intensified in'he second half of the "appraisal'eriod with over 300 engineer and clerical personnel performing a 100! review of all procurement and installation

records.

No NRC items of noncompliance were identified relative to,the review effort.

Initial Bechtel efforts demonstrated loss of process control as identified by the ASNE authorized inspector; the specific matters have since been resolved.

One NRC item of noncompliance was identified relative to adherance to procedures for removal of piping surface defects.

The matter has since been resolved.

Bechtel has also experienced difficulties in controlling materials, and has identified document control problems in lost weld records.

These matters suggest a continued weakness in process control.

This area has been identified by the licensee quality as'surance department which is attempting to effect improvements.

b.

Conclusion n

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Category 2.

Board Recommendation NRC inspection activities should examine Bechtel current work activities'.to ascertain adequate process control.

4.

Safet Related'Com onents and Su ort S stems a ~

~Anal sis s

During this assessment period significant inspection effort was directed at evaluation of the licensee's actions with respect to reported construction deficiencies of safety related components.

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Notable were the reported leakage of the spray ponds and the requirement to upgrade the safety classification of the installed fuel'pool cooling system to prevent flooding of the emergency core cooling system pump rooms.

'The licensee had reported that the spray ponds had unidentified leakage.

A test program was devised and the source of the leaks were determined to be the construction joints in the concrete slab structure of the spray ponds.

The original sealant material was

removed, some concrete
removed, the water stops repaired and new sealant material added.

This work appeared to be satisfactorily carried out.

Leakage tests are planned during the startup phase of construction.

The fuel pool cooling system,

however, had not been upgraded in accordance with the provisions of the licensee's 1979 construction deficiency report.

The licensee during this assessment period was preparing a draft FSAR amendment to define this system in accordance with the deficiency report.

Regional inspectors were unable to confirm that field modifications had been made to meet the additional requirements.

The safety significance of these modifications will not arise until after the first refueling.

b. 'onclusions Category 2.

c.

Recommendations Licensee should place additional emphasis on insuring implementation of corrective actions defined in construction deficiency reports.

5.

Electr ical Power Su 1

and Distribution a.

~Anal sos

%~f A major area of concern, discussed in the last assessment

period, involved the lack of.. a clear definition of acceptance criteria for s

insuring, the electrical independence of redundant safety related circuits.

The licensee s criteria, which had been submitted as a response,to NRR question 031.100, was found to be not acceptable to the NRC.

A revised criteria, submitted in June,

1981, was not clearly reflected in FSAR Amendments submitted in Hay, 1982.

This new criteria is presently under NRR review.

The regional inspection program remains uncertain of the status of the current installation with respect to acceptable independence criteria.

During this assessment

period, Burns and Roe continued to hold this problem within their organization. 'he installation contractor, the construction manager,'nd the licensee have not taken an active part in assuring

.the quality of electrical installations with respect to separation criteria.

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Outstanding deficiencies, identified by the licensee as early as 1978, in the separation and identification of cables within the power generation control complex remain unresolved.

Conclusion c ~

Category 3.

Board Recommendations A major review of electrical installations to verify conformance to acceptable independence criteria is required.

6.

Instrumentation and Control S stems a ~

~Anal sls The licensee has continued the improved program of equipment protection discussed in the last assessment, and continues an agreessive program of resolving identified problems.

During this assessment period two enforcement items were identified in this area, related to unqualified bending of tubing.

These items have been resolved by the licensee.

b.

Conclusions c ~

Category 2.

Recomendations None.

7.

~Licensin a ~

~Anal sis n

Specific licensin'g actions involved review activities related to licensee qualification, containment

systems, auxiliary systems, reactor "systems, materials engineering, chemical engineering and geology/seismology.

There is strong evidence of management involvement and control in assuring quality as evidence by the planning and assignment of priorities and decision making at a level that ensures management review.

Management involvement was particulary evident in, resolving the NRR and, United States Geological Survey (USGS) concerns in the geological and seismological areas.

The resolution of technical issues was particulary evident in the containment systems area where the licensee undertook a major evaluation effort to justify deviation from generic resolution in the pool

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Responses to NRC review, questions on FSAR submittals

"'we'e* usually delivered within the time frame specified.

In a few cases NRC request dates were missed due either to the quantity of effort required or to the licensee's uncertainty of the NRC request.

This was true in the geology/seismology review area.

However, the final responses were of good quality.

The licensee makes a concerted effort to be very responsive.

r The Licensee gualification Branch found that the licensee had already filled key and other staff positions.

Also, the licensee defined and implemented a satisfactory training program for its staff.

The licensee.satisfactorily resolved last years outstanding issue related to timeliness of response to requests.

The licensee has been characterized by NRR as being knowledgeable, cooperative, technically competent and responsive in the area of licensing activities.

Conclusions Category 1

Board Recommendations 8.

~ No outstanding issues.

Design Control

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~Anal sis The area of design control was examined on several occassions, culminating in an extensive review at the site and at the architech-engineer's (Burns and Roe, Woodbury, New York Office) in May and June 1982.

These inspections focused on the design verification/review process for compliance with 10 CFR. 50, Appendix B since the licensee is not committed to Regulatory Guide 1.64 or ANSI N45.'2.11.

The calculation drawings, and specifications performed in, the Burns and Roe, Woodbury Office have undergone a design review consistent with the design control requirement stated in the WNP-2 FSAR, Amendment No.

23 and 10 CFR 50,

'Appendix.B.

However, a deficiency was identified with the Project Criteriai Document, in that the associated engineering design guides were not 'required to be controlled.

One copy of Project Criteria Document was'ound to'e out of date and one design guide was not contr'oiled.

The program was subsequently changed and documents

",properly'ontrolled.

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(he licensee conducted an extensive examination of contractors performing design work.

The NRC also examined records pertaining to the design performed by several contractors reporting to Burns and Roe, kloodbury Office.

Results of these separate

,'eviews showed, that the contractors complied with the design review requirements of 10.CFR 50, Appendix B.

F< n The licensee has an outstanding back log of items for which

,'performance standards have been established and is monitoring

these outstanding items.,I Conclusions' I

I Category 2

Board Recommendations

'No further NRC inspections on the design review issue appear warranted.

9.

Radiological Controls:

a.

~Anal sis The initial preoperational inspections of the licensee's radiation protection program were performed during the evaluation period.

These inspections found a well developed organization staffed by experienced technicians and professionals engaged in establishing and implementing a quality radiation protection program.

Although some areas for program improvement were identified, it seems reasonable to expect that the licensee will complete implementation of their radiation protection program by the scheduled September 1983 date contingent on continued support at the present level.

b.

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Conclusion:==

Category 2

c.

Board Recommendation:

Implementation of the normal inspection program is appropriate in view of the licensee's demonstrated commitment.

10.

uality Assurance a.

~Anal sis During the prior appraisal period. some improvements were noted in the licensee action on the resolution'f the large backlog of outstanding NRC open items.

During the current period the new

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V' construction manager (Bechtel) assumed responsibility for resolution of the backlog of NRC inspection findings.

All items previously identified by NRC inspectors were reviewed to identify continuing commitments involving work methods and to avoid recurrence of the identified problems.

The Bechtel quality assurance organization assured that these commitments were incorporated into contractor and/or Bechtel work procedures and provided the data base to contract administrators for use in future procedure revision reviews.

However, similar actions were aparently not taken relative to applicable licensee or engineer procedures.

A special NRC team inspection of the Supply System and Bechtel quality assurance program was conducted September 1981 with generally acceptable findings.

Reviews of licensee actions on open items generally found such actions to have been acceptable.

b.

Conclusion Category 2.

c.

Board Recommendation None.

11.

Reverification Pro ram a.

~Anal sis The reverification program was initiated to address the concerns identified in the 10 CFR 50.54(f) letter from the Commission to the licensee dated June 17, 1980.

The licensee's program as presented to Region V in a meeting in November 1981 is documented in a guality Verification Instruction Manual dated June 1981.

The construction manager has a Reverification Group providing management control over site contractor activities to assure compliance with the licensee's commitments to the NRC.

NRC inspection results show that the licensee has been fullfillinghis commitments and programatically looks good.

The reverification program has been completed for several contractors without the identification of any unknown deficiencies.

There may be a trend toward a reduction in staffing as emphasis shifts towards other areas of interest.

The Board believes this effort should be continued to its ultimate conclusion.

Also, the Board is concerned that, the sample size may not be adjusted once a defic'iency is identified, i.e. potential to characterize discrepancies as being isolated cases rather than generic in nature.

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'k The licensee conducted an assessment of the reverif'ication program in April 1982.

The assessment team concluded that the reverification program was in place and working.

Some areas needed clarification or course direction to assure compliance with the NRC 10 CFR 50;54(f) commitments.

The MPPSS guality Verification Program group is taking action to respond to the perceived strengths/weaknesses and recommendations identified in the assessment team report.

'onclusions Category 2

Board Recoranendation Monitor program to its ultimate conclusion.

12.

"0 erations Plant'0 erations/Maintenance ualit "Assurance and Prep erational "Testin a ~

'~Ana1 sis

- Only two inspections were made in this general area during the SALP review period since the preoperational test program has not fully commenced.

IResults of these inspections showed the following:

1 (1)

The plant, staff and operator training program was being

,completed in a timely manner to support projected plant operations.

1 (2)

Maintenance has control of approximately 60/ of the total

'lant components.

Maintenance has been involved primarily in

. supporting;-the -startup organization and implementation of the preventive maintenance program.

A formal training program has been defined for maintenance personnel.

Maintenance procedures have been developed and are being evaluated during ongoing preventative maintenance activities.

(3)

The Operations guality Assurance and guality Control organization has been formed and is actively involved in the project.

The training program for personnel has been defined.

The organization appears to have asserted itself on the plant Review Committee.

(4)

Very little preoperational test work with safety-related systems has been performed by the licensee in the area.

Most of the work has been programatic in nature.

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Recommendation Continue routine inspection program for preoperational testing of systems.

13.

Corrective Actions a.

'Ana1 sos Since the last appraisal period the licensee has completed work restart and proceeded with corrective action implementation and project completion activities.

The corrective actions included conduct of a reverification program for work completed prior to June 1980.

This encompassed record reviews and re-inspections of hardware.

The program appears to be well defined and integrated into the overall project completion plans, and this regard represents a significant strength.

Results of the effort remain to be assessed by NRC inspection.

Intensive attention was given to the review and corrective actions for records of'he mechanical contractor, which had previously been identified as containing significant discrepancies.

Manpower and planning appeared adequate.

The effort.was administered by senior personnel of the construction manager organization and was audited and monitored by the contractor and construction manager quality assurance organizations, including reported 100-percent reviews of procurement documentation and large samples of installation documentation.

During the review/disposition efforts, the resident inspector did not encounter any reports of inadequate review of dispositions, despite the large numbers of review personnel involved.

Dispositions of identified discrepancies were.sampled by NRC inspectors and showed conservatism and were technically sound.

This review effort and the resultant confidence achieved by the licensee in the adequacy of the records and associated hardware is a significant strength.

Routine NRC inspection of the final records remains to be accomplished.

The construction manager conducted an intensive. effort to re-review all radiographs previously performed. by the mechanical contractor.

Some questions remain unresolved relative to the licensee's basis for not con'sidering film quality as a review criterion for a large percentage of the radiographs.

However, the reviews appear to have been conservative and represent a significant strength in achieving confidence in the quality of existing reactor coolant boundary welds.

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~I4 II During the previous appi aisal period NRC noted that absence of an effective tracking system for NRC open items had contributed to a large backlogs of issues.

Tracking systems have been developed and responsible 'personnel assigned for followup actions.

Some issues are longstanding due to the complexity and long term integration into routine project completion activities.

This area has improved.

During the previous period the results of the work restart effort showed deficiencies for control of work by the mechanical contractor.

Since then Bechtel has assumed responsibility for future work under its established quality assurance program.

The specific matter of questionable work procedures has improved, although the Bechtel program is experiencing some weaknesses.

During the previous period the reverification program had not made sufficient progress to permit assessment of (1) sample size selections, (2) credit for reviews by other contractors, (3) thoroughness of document review and re-inspection checklists, and (4) acceptance criteria effectiveness in verifying adequacy of previous work.

Progress has been made in defining criteria, procedures and sampling bases.

Limited data suggests that this activity has improved.

However, there appears to be a trend toward a lack of personnel staffing to adequately verify the activities of the reverification program and an apparent reluctance to increase the sample size once a deficiency has been identified.

During the previous period NRC noted that the licensee had overlooked some commitments to NRC.

Modified approache's and plans for problem resolutions was a perceived weakness.

The licensee has given increased attention to NRC commitments and has effected improvements in this area.

However, there have been cases this period where the licensee approached problem resolution in a manner different than that formally committed to the NRC, and delayed notifying the NRC of these changes.

One such item involved the reduction of hardware inspections from 100-percent to 10-percent as related to special requirements checklists.

This area represents a continued weakness in the licensee's program.

P Existence of large backlogs of open items was previously a perceived weakness.

The li'censee has developed project wide performance standards for backlogs and monitors this area by senior management.

Some significant downward trends have been effected.

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Category 2.

Board Recommendation Continue inspection of Bechtel implementation of its quality assurance program.

Give priority to evaluation of results and dispositions of reverification program.

Give priority to inspection of'-final documentation of mechanical systems after completion of the l)BG effort.

14.

Im lementation of Pro osed Corrective Actions to Resolve Re orted Construction Deficiencies I

a.,~Anal sis,',

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period, an effective tracking system for insuring ithplementation of proposed corrective actions to resolve repo'rted construction deficiencies, remains absent in the licensee s

program.

Many of, the issQes reported by the licensee under 10 CFR 50.55e requirements, remain unreso]ved long after the licensee's final report submittal.-

Notable among these are deficiencies in the fuel pool cooling system installation, concrete expansion anchor installation, load-bearing grout installation, and independence of redundaht circuits within the power generation control complex.

Final reports on these deficiencies were submitted as early as 1979.

However, corrective actions did not appear to have been properly implemented during the assessment period.

b.

Conclusion Category 3.

c.

Recommendations The licensee should devote additional effort to insuring that proposed corrective actions to reported construction deficiencies are fully implemented.

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SUPPORTING. DATA AND SUMMARIES The following tables provide supporting data and sumaries.

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'TABLE I

'IGNIFICANT CONSTRUCTION DEFICIENCIES DOCKET NUMBER:

50-397 (WNP-2)

EVALUATION'PERIOD: July 1, 1981 - July 31, 1982 10 CFR 50.55 e)

DEFICIENCIES FIRST REPORTED DURING THE EVALUATION PERIOD ITEM 81-09-A 81-11-A 81-12-B 82-02-A 82-03-A 82-05-A 82-05-B DESCRIPTION Generic QA failure; DG air inlet with metal chips, stick in RHR pump volute (215 contract).

Unacceptable radiographic film and techniques.

Borg Warner valves ordered by WBG do not meet design corrosion tolerances Piping outside 21 penetrations designed for 150 F

service vice LOCA 340 F service.

Type SV9 and SVM switch problem.

1 hr rating of DG feeder cable may be exceeded.

Excessive voltage drop on size A starter for HPCS STATUS Final Report (NRC review pending)

Final Report (NRC review pending)

Final Report (NRC review pending)

Closed Closed.

Report pending Interim Report (NRC review pending) 82-07-A Battery charger 200 amp fuses too small.

Final Report (NRC review pending) 82-07-B 8 of 89 process lines overstressed by thermal expansion Interim Report (NRC review pending)

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TABLE 2 INVESTIGATION ACTIVITIES A significant amount of inspector effort was expended in the investigation of allegations.

The specific allegations investigated included:

1.

Destruction of guality Records.

2.

Voids in Concrete.

3.

Alteration of Documents.

4.

Crack 'in Sacraficial Shield Mall.

5..

Crack,in concrete in wet well columns.

6.

Listing of Reactor pressure Vessel.

7.

Lack of reinforcement steel in the 501 feet elevation slab in containment.

8.

Containment insulation covering cap rupture.

9.

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16.

Cya~i'de gas released when containment insulation temperature reaches 500 F and ignites.,

Inadequate protection instake system pipes.

Cadweld maps missing.

Hain Steam line penetrations short.

Nonconformance Reports not processed.

Inspections not pe'rformed on fire protection systems.

No preheat on some pipe hangers.

gG Inspections done to information drawings.

17.

Oxygen analyzer not calibrated.

18, gC inspections performed prior to scoping.

I 19.

Torque wrenches not recalibrated.

20.

Reuse of 1 ockwashers.

21.

Mater loss from spray pond.

I 22.

Improperly placed rebor in base mat.

Only one item was substantiated; number 3, alteration of documents.

The issue was resolved by obtaining new documents from the vendor source.

None of the other allegations could be substantiated.

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TABLE 3 ENFORCEMENT ACTIONS DOCKET NUMBER:

50-397 (IrlNP-2)

EVALUATION PERIOD:

July 1, 1981 - July 31, 1982 ITEM NUMBER SEVERITY 397/81-21/01 397/81-21/02 DESCRIPTION No QC inspection requirements for arc strike acceptance/testing Failure of field weld engineer to accompany QC inspector during arc strike evaluations FUNCTIONAL AREA Piping Systems Piping Systems 397/82-14/01 397/82-14/02 IV IV Pipe bent without procedure or approved bender NCR not issued to control nonconforming material and preclude its inadvertent usage.

Instrumentation Contractor Instrumentation Contractor

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TABLE 4 INSPECTION HOUR

SUMMARY

DOCKET NUMBER:

50-397 (WNP-2)

'EVALUATION PERIOD:

July 1, 1981 - July 31, 1982 INSPECTIONS

'umber Hours Onsite Hours In Office REGIONAL-BASED 15 1040 127 RESIDENT 12 873 Functional Area S'oils 8 Foundations Containment 8 Safety Structures Piping Systems Safety Components Electrical Systems Instrument-'.and Control Systems Design Control Radiological Controls equality Assurance Reverification Program Plant Operations

Corrective Actions Reported Construction Deficiencies Allegations Other (Approximate)

Ins ection Effort 2%

5%

10%

5%

3%

5%

10/

3/

5%

12%

3%

10%

12%

10%

5%

100%

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1 I

4 N

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