ML20004F236

Submits Fourth Bimonthly Progress Rept Re safety-related Work & Mgt Sys Concerning Restart Activities.Verification Program Utilizes Resources of Supply Sys & Sys Completion Contractor

ML20004F236
Person / Time
Site:	Columbia
Issue date:	05/15/1981
From:	Matlock R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
EA-80-020, EA-80-20, G2-81-99, GO2-81-99, NUDOCS 8106160652
Download: ML20004F236 (13)

Text

{{#Wiki_filter:f'D g/8r cPPl/r) nh u p / y P Washington Public Power Supply System ,2 JUN 151981 > =! A JO'NT OPERATING AGENCY Ese J' g -{7 S P. O. 50 s S e e 3000 Geo. Wassesasroes way R cwLamo. Waeuswerose 99352 w S i41 S 00 May 15, 1981 G02-81-99 Nuclear Regulatory Commission Region V, Office of Inspection and Enforcement 4 Suite 202, Walnut Creek Plaza 9ECFNEO M 1990 North Califomia Bculevard S" MAY 201C81 6 Walnut Creek, California 94596 ,cc.ay lNSPECDOM & r Attenti on: Mr. R. H. Engelken, Director ENECRC M t Gentlemen:

Subject:

WPPSS NUCLEAR PROJECT to. 2 DOCKET NO. 50-397 FOURTH PROGRESS REPORT - 10CFR50.54(f)

Reference:

1) G02-80-153, N.0. Strand to UStRC, "WPPSS Nuclear Project No. 2, Docket No. 50-397, EA-80-20, Notice of Violation and Additional Inf ormation - 10CFR50.54(f),"

dated July 17, 1980. *

2) G02-80-259, R. G. Matlock to UStRC, "WPPSS Nuclear Project No. 2, Docket No. 50-397, WNP-2 Management System Description," dated November 12, 1980.

3) G02-81-56, "WPPSS Nuclear Project No. 2, Docket No.

50-397, Third Progress Report - 10CFR50.54(f)," dated March 12, 1981. This is the fourth bi-monthly Progress Report on the actions we have taken in regard to our conrnitmerits in References 1 and 2. I Substantial progress has been made in the Restart Program during this reporting period. Fourteen (14) activities were released for restart and the Ta-k Force reviews of the remaining eleven (11) are nearing the completion stages. I fully expect most of the planned restart activities to be completed before June 1,1981. Details of our progmss on e con-tractor basis are more fully described in Attachment 1. 0 \\q'71( t 81001 coloSL BI - BB Q

~ Mr. R.H. Engelken Page 2 WPPSS Nuclear Project No. 2 Docket No. 50-397 Fourth Progress Report - 10CFR50.54(f) Planning for the Reverification Program activity continues. A quality verification program is evolving which addresses the adequacy of past work and the supporting documentation. The program util-izes resources of the Supply System and the Systems Completion Contractor, and provides an overall integrated plan for examining documentation and hardware. Docu-mentation review-. Tre currently underway and hardware reinspections are expected to begin ut the next reporting period. A formal presentation of this Reverification Program to Region V personnel is anticipated during the next reporting period. Coincident with the completion of the Restart Program, the bulk of the management systems work assigned to Task Force III is also nearing completion. Hpwever, the management systems overview activity will continue throughout the completion of the Reverification Program to disseminate additional lessons learned from this activity. Details of Task Force III activities are contained in Attachment 2. Should you have any questions regarding the nature or content of the re-view program or the report, please feel free to contact me at your convenience. Very truly yours, i R.s. Matlock Piogram Director, WNP-2 Attachments:

1) Review of Completed Safety-Related Work -

Progress Report

2) Assure The Managenent Systems Used To Control Continuing Work Are Adequate -

Progress Report cc: N.D. Lewis, EFSEC, A 20 E. 5th St., Olympia, WA. 98504 W.S. Chin. BPA R.C. Root, B&R, WNP-2 J.J. Verderber, B&R, 185 Crossway Park Dr., Woodbury, N.Y. 11797 J.B. Knotts, Jr., Debevoise & Libennan, Shoreham Bldg., 1200 17th St. N.W., Washington, D.C. 20036 A.D. Toth, NRC, Resident WNP-2 ey e m-7---.--- v g w-m w 4 -,s-w y 4

j ~. ATTACHMENT 1 TASK FORCE II REVIEW 0F COMPLETED SAFETY-RELATED WORK PROGRESS REPORT A. INTRODUCTION This attachment is keyed to the underlined statements in Attachment I of the Supply System response (G02-80-153) to the USfRC 10CFR50.54(f) letter (EA-80-20 ). Statements from the response letter are repeated (underlined and keyed to response letter paragraph) and these are followed by our progress response. The response statements have been arranged into four groups: 1) Management Practices and Controls; 2) Task II-Phase 2; 3) Schedule; and 4) Restart Activities, Task II-Phase 1, to allow meaningful progress reporting, eliminate redundancy, and reduce referencing to other sections of the report. B. MANAGEMENT PRACTICES AND CONTROLS C-1 Review of records, installation and hardware will be accomplished under Owner direction and control. C-2 The review shall be integrated with on-going plans and' management ~ ~ systems to assure proper feedback to on-going work and to adjust the review in response to knowledge acquired. C-3 This' program will have priority over on-going work. The Project construction work pace will be adjusted accordingly. C-4 The basis for key decisions will be documented. E-2-2 Determine whether other inspection or evaluation programs have sat-isfied or will satisfy the requirements of this program. No major changes were made to the above elements during this reporting period. C. TASK II - PHASE 2 4 B-1 Determine whether the Quality Assurance Program was adequate in the past to assure completed safety-related work was properly performed. B-2 Identify the need for repairs or further actions. E.2.3 Record Rr. view. E.2.4 Receipt Inspection. E.2.5 Installation Reinspections. E.2.6 Deficiencies. Deficiencies identified during the performance of record review, reinspectiomoF installation and reinspection of received material shall De documented. %js i 1-1 -i h

An analysis of the number and types of deficiencies identified shall be perf ormed to determine the root cause of the problem and appro-priate corrective action initiated. Relevant information will be communicated to all Projects. The Supply System has re-examined the above cannitments, as well as the con-cerns they were designed to address, to determine the effect of the planned transition from bulk construction to systems-oriented constructi_on. As a result, a quality verification program is being prepared which considers the previous commitments outlined in G02-80-153, and describes the review of past ' work for each of the following three activities: a) Systems Completion Verification reviews of documentation and sample reinspections of hard-ware, which are to be accomplished on a Startup-System basis, b) Prepurchase and Inactive Site Contracts Similar reviews and reinspections, which are to be completed on a contract-by-contract basis, and which will be coordinated to meet systems-completion construction schedules. c) Special Tasks Similar reviews and reinspections as appropriate for specialized activi-ties which do not lend themselves to a) or b). These include such tasks as deficiency document reviews for correctness of disposition and receiv-ing reinspection. ' The detail planning for the quality verification program is nearing completion and this activity is anticipated to begin in the next reporting period. D. SCHEDULE E.2.1 Determine the criticality and priority of items for review and/or reinsp ecti on. -A is the latest schedule for the Restart Program. Two commodity additions were made during this reporting period, bringing the total to thirty-one (31) activities. Contract 210 (Peter Kiewit Sons) was added to cover miscellaneous civil activities and the remaining Sacrifical Shield Wall Weld repairs were identified as a separate commodity item. The schedule for the quality verification program (Task II-Phase 2) is under development. 1-2 ---e

s-E. RESTART ACTIVITIES, TASK II-PHASE 1 General There were no changes made to the approved Restart Program Plan during this reporting period. Attachment 2-C in Progress Report Number 3 is the current plan. E-1 Identify all contractors, subcontractors, anc. are-purchased equip-ment contractors performing safety-related worc, the status of their work, and '.ne status of final documentation review. Contractors and subcontractors performing safety-related work have been ident-ified and the status of their work is being reviewed on a commodity basis to support the restart schedule (Attachment 1-A). Specific progress toward restart of the major conthai: tors is presented in the following sections. 1. Contract 220 - Johnson Controls Progress Report Number 3 reoarted the completior, ir the restart program activities for this contractor. _ 2. Contract 216 - Waldinger Corporation The final, documentation packages were completed and the contractor was conditionally released to restart work on all assigned comodities on March 13,1981, except f or work covered by the MCC-Powers subcontractor. 3. Contract 215 - Wright-Schuchart-Harbor-Boecon-Geri The restart program final documentation packages were released on April 28, 1981 for review by Project Quality Assurance, the Independent Review Team, and the Resident tRC Inspector. The commodities covered by these data packages are: l o Remanuf acture and Repair of Pipe Whip Restraints I Large and Smal', Bore Hangers, Concrete Inserts, and Installation of l o l Pipe Whip Rescraints i Large and Small Bore Pipe except CRD Piping l o Repair of SSW Accessible External Welds to AWS D1.1 Visual o Acceptance Standards 1-3

w The conrnodities not included in these documentation packages are: e WBG Prime Work 1. Cathodic Protection 2. Structural Steel 3. Mechanical Equipment Installation 4. Instruments 5. Civil Work - Currently being assigned to PKS, except grout-ing, and includes excavation, compacting, rebar placing, cadwelding, concrete placing. 6. Spent Fuel Racks 7. Heat Tracing e WBG Subcontractor Work 1. Brand Insulation - Reflective and C'alcium Silicate on RPV, piping, and equipment. 2. Chemtrol - Watertight boots (all work presently installed QC II, but PED has been issued to upgrade to QC I.) CRD System (Pipe, Hangers, and Equipment), CRD 3. GE/I&SE Handling Crane, Ref'ueling _ Crane, RPV Internals. 4. Concrete Coring - Concrete Drilling Of the 117 procedures identified for Contract 215, 105 have been sub-mitted and are in the ' final approval process, this total also includes one subcontractor. (NIX Testing) As a result of review of NRC concerns and findings, it became evident that a more systematic verification of closure of these items was re-quired. A team has been established under PQA to review each open NRC item to assure adequate resolution prior to restart of affected commodi-ties. 4. Contract 213A - Pittsburgh-Des Moines The final documentation packages were completed and the contractor was released to restart work on the remaining commodities on April 1,1981. The release for the weld pad coninodity was reported in Progress Report Number 3. 5. Contract 218 - Fischbach/ Lord Final docJmentation packages for the remaining commodities assigned to Fischbach/ Lord were completed and the contractor was released to restart l construction work activities on April 2, 1981. Release of Receiving Inspection was covered in Progress Reprrt Number 3. l l 1-4 3

6. Contract 234 - 0.B. Cannon The Concrete Substrate Coating final documentation package was completed and the contractor was released to restart work on this comodity on Feb-ruary 6, 1981. _The Task Force review led to a joint rewriting of 0.B. Cannon's Quality Assurance Program and Construction Procedures to comply with the specification, standards and applicule codes. Through this joint effort the procedures were developed, reviewed, and comented on by Task Force II. The Steel Substrate Coating final documentation package was completed and the contractor was released to restart work on this comodity on April 20, 1981. 7. Contract 219 - 0.B. Cannon The Special Coating's final documentation package was completed and the contractor was released to restart work on April 14, 1981. The Task Force review led to a joint rewriting of 0.B. Cannon's Quality Assurance Program and Construction Procedures to comply with the specification, standards and applicable codes. Through this joint effort the procedures were developed, reviewed, and commented on by Task Force II. There are now twenty-four (24) approved procedures which include a Qual-ity Assurance / Quality Control Program and Construction Procedures for the application of special coatings to concrete / steel substrates. The o,ne remaining procedure, pertaining to the application of special coatit g to concrete substrate (system SPC-05) will be reviewed and approved prior to restart of those activities. 8. Contract 217 - Sentry Task Forct identified forty-six (46) procedures to be reviewed. Proce-dure review was completed on all procedures and comments have been acceptably resolved for forty-four (44) procedures. The two (2) remain-ing procedures are currently in the final revision process and am punch listed. l The final documentation package was completed on May 1, 1981 and it has been submitted to Project Quality Assurance for review. l 9. Contract 210 - Peter Kiewit Sons l The 210 contractor, Peter Kiewit Sons, has been added to the Level III Restart Schedule. Twenty-seven (27) procedures have been identified as l being required to begin Class I work. The Task Force has completed in-l itial review of 16 of the required 27 procedures. Contracter is cur-rently refising these 16 procedures to incorporate Task Force coments. The contractor is also upgrading his QA Manual. The projected restart l date for Contract 210 is May 8,1981. 1-5 s M

to E-2.6.2 Deficiencies in meeting the requirements of 10CFR50.55(e) and/or Part 21 shall be reported to the NRC in accordance with approved procedures. Others shall be summarized in tre bi-monthly report to the NRC Reoion V Office. The Task Force II, Phase I, Restart Program review findings through April 30, 1981 date are shown in Attachment 1-8. The Software Findings Analysis and the Hardware Findings Analysis de-scribed en pages 3, 4 and 5 of Attachment 2-0 of Progress Report Number 3 have not been included in this report. The procedure reviews continued to generate similar findings for each contractor and therefore the Pro-gress Report Number 3 analysis is representative of the results of this activity. Overall, over 600 procedures were evaluated and over 1800 significant comments are compiled in the applicable final documentation p ackages. The Hardware inspections were discontinued in December 1980 and this in-formation will be updated with the commencement of the Quality Verifica-tion Program activities. 4 e d 1-6 ~

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l. RESTART PROGRAM - REVIEW STATUS ATTACHMENT 1-B Page 1 of 1 PROCEDURE PERSONNEL DEFICIENCY REVIEWS OUALIFICATIONS REVIEWS I C R I C R I C R O 0 E D 0 E D 0 E C0tN00lTY TITLE E M M E M M E M M N P A N P A N P A CONTRACTOR T L I i L I T L I E N E N E N T T T E E E GIRTH WELD REPAIR 23 23 0 22 22 0 387 387 0 WBG PDM 72 72 0 29 h9 0 290 290 0 LARGE BORE HANGERS, AND PWR-REFAB WBG 4 + LARGE & SMALL BORE 117 105 12 N/A 501 501 0 PIPING REPAIR OF SSW i . ACCESSIBLE EXTERNAL WELDS SPECIAL C0ATINGS 59 48 11 13 13 0 112 112 0 0.B. CANNON (219 & 234) .= ALL 117 93 24 10 10 0 88 88 0 FISCHBACH/ LORD P.I. PIPING 63 63 0 15 15 0 166 166 0 l JOHNSON CONTROLS WALDINGER 12 9 119 10 26 26 0 99 99 0 216 SENTRY AUTOMATIC 46 44 2 N/A 39 39 0 l l 217 SPRINKLERS i ' PETER XIEWIT 27 0 27 N/ 's In Progress l 210 TOTAL 653 567 86 151 151 0 1682 1682 0

ATTACHMENT 2 TASK FORCE III ASSURE THE MANAGEMENT SYSTEMS USED TO CONTROL CONTINUING WORK ARE ADEQUATE - PROGRESS REPORT COM4ITMENT: 1) Focus on improving methods throughout the organization to systematically identify and correct underlying causes of problems in a timely manner. 2) Perform analysis of results from " Resolution of Concerns / Problems' (Task Force I) and " Reverification" (Task Force II) f or application to any necessary changes to management controls for WNP-2 Project and con-tractors' organizations. Consider management system. changes made over the past two years and determine the need for adaitional improvements. 3) Perform reviews of various, previously perfonned consultant studies re-garaing quality assurance improvements for WNP-2 Project. 4) Transmit knowledge gained in reviewing past work at WNP-2 to the other Supply System projects to permit evaluations of their management control sy stems. GENEP.M. The commitment objectives to strengthen overall management control systems at the WNP-2 Project and to disseminate the significant lessons learned to other Supply System projects was described in Progress Report Number 3. Six (6) Lessons Learned Bulletins have been issued through April 1981. About one third of the twenty-one issues disseminated to all Supply System Nuclear Projects have originated f rom the experiences at WNP-2 Project. With the Restart Program nearing completion, the bulk of the managements sys-tems work related to the control of continuing work is nearing completion. However, the Lessons Learned activity and the application of knowledge from and to the Reverification Program will continue. These activities will continue to be reported as a Task Force III activity. PROGRESS Progress is reported against the commitments and topics described in Progress Report No. 3 (Reference 3) 2-1 -.-,---,c - - ~ r -- n r g a,--- w~,--n ~p---,

5. 1. Improving Methods A. Major Mechanical Contractor The Supply System performed another evaluation and spot check of the WBG Management System on April 21-24, 1981. This review found that the system was being used, that internal audits were adequately uncovering both system and performance deficiencies and that internal corrective actions were effectively dealing with both issues. Procedural clarification and finalization activities are continuing on some of the essential activity con trols. However, the management control system is considered adequate to control continuing work a:tivities pending comple-tion of the issues now under resolution by the Restart Program. No further reviews or evaluations by Task. Force III are plan-ned. The WBG Management Control System is now a controlled document approved by the Supply System and subject to the nor-mal project internal / external audit / surveillance controls. B. Other Contractors These activities wre reported in Progress Report Number 3 and are considered complete from a Task Force viewpoint. C. Project Improvement 1. 'The need for a WNP-2 Project Master Flow Chart describing major project management - contractor interf aces and the supporting sub-flow charts is being reassessed. This activity is still in progress. 2. Analysis of Results A special task has been initiated to extract lessons and knowledge learned f rom the Task Force II, Phase 1 work ac tivities. This information will feed into both the Re-verification Program planning and into the Lessons Learned t ac tivity. The review of final documentation packages is now in procets. 3. Consultant Studies Completed in Progress Report Number 3. 4. Transmit Knowledge Gained This is a continuous activity. Progress Report Number 3 reported on the methods established to meet this commit-ment. e 2-2 (

D. Management System Modification This section has been added to report modifications to the state-ments in Reference 2. 1. WBG Management System Modifications a. Paragraph 2.1 of Attachment 2 to Reference 2. required craf t personnel to be tested to all work proccdures. This requirement was clarified to require training of all craft and non-manual personnel and testing of all non-manuals. Craft testing to individual work procedure is mquired only where there are specific prescribed requirements in the approved training program; e.g. welding, N0E, etc. b. Paragraph 3.7.3 of Attachment 3 to Reference 2 required the originator of an inspection report (IR) to receive a copy of the dispositioned report. Procedures were esta-blished to assure that the IR criginator does mceive a copy of each voided or otherwise unacceptable IR. Copies of all dispositioned IR's are available to any inspector at all times. This provision meets the original intent of the above consnitment... ~..-- - t '1 G 2 -3 e -c- _,p. ,,,}}