ML20010H706

Forwards Evaluation of Licensee Performance for Systematic Assessment of Licensee Performance Review Group Evaluation. WNP-2 Enforcement History, Also Encl

ML20010H706
Person / Time
Site:	Columbia
Issue date:	06/18/1980
From:	Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML17272A975	List: ML17272A974 ML20010H696 ML20010H699 ML20010H700 ML20010H702 ML20010H703 ML20010H706 ML20010H707
References
FOIA-81-223 NUDOCS 8109290170
Download: ML20010H706 (1)

Text

{{#Wiki_filter:s. p nee ~ Cy* q,) ' Yli ' l' l o !aNITED STATES k. '[ I{ . NUCLEAR R5CULATORY COMMISSION y,[./ F - e REGION V g l 1990 N. CALIFORNIA BOULEVARD l

1. g SUITE 202. WALNUT CREEK PLAZA

• e,,*

WALNUT CREEK, CALIFORNIA 94596 ~ JUll 181980 MEMORANDUM FOR: H. D. Thornburg, Director, Division of Reactor . Construction Inspection FROM: G. S. Spencer, Chief, Reactor Construction and Engineering Support Branch S'tBJECT: REGIONAL EVALUATION OF LICENSEE PERFORPANCE AT WNP-2 Pursuant to OIE Manual Chapter 2955, the enclosed regional evaluation of licensee performance at WNP-2 is forwarded for the SALP Review Group's evaluation. Copies of the regional evaluation and supporting data, except for the Action Plan, Table A and_the Inspection Frequency / Scope. evaluation sheet, were recently forwarded to the licensee and NRC's Public Document Room. Also enclosed is the project inspector's evaluation of April 18, 1979 of licensee performance for the period immediately preceding the regional evaluation. The notes on the project inspector's evaluation here made by him at the time of the recent regional evaluation. Additionally, enclosed is a graph, "UNP-2 Enforccment History", relating the noncom- 'pliance history With time, construction progress and NRC inspection hours. 7 y G. S. Spencer, Chief a Reactor Construction and Engineering Support Branch

Enclosures:

As stated T a 4.@ '8109290170 810805 / .PDR FOIA iBRYAN81-223 PDR L/

. p f a "%g[e, i s[i71 ;e, ,g NUCLEAR REGULATORY COMMISSION UNITED STATES - 5g a REGION V 2 e,1,dr 1990 N. CALIFORNIA BOULEVARD % *\\ SUITE 202, WALNUT CREE K PLAZA WALNU1 '.R EE K, CALIFORNIA 94596 f,'g MEMORANDUM FOR: G. S. Spencer, Chief, Reactor Construction and Engineerinti Suppo t Branch FROM: Regional Evaluation Review Board - WNP-2

SUBJECT:

NRC REGIONAL EVALUATION OF WASHINGTON NUCLEAR PROJECT N0. 2 (WNP-2) The Regional Evaluation Review Board for WNP-2 met on May 7,1980, to perform the evaluation of project activities for the period of April 1979 through April:1980. The board reviewed the following areas: a.- Previous enforcement actions and results (including escal'ated enforcement actions) b. Licensee's resporsiveness and ability to execute corrective actions.identif#ud by the NRC and licensee managemt at systems. 4 c. Licensee actions in the area of IE Bulletins, Circulars, licensee event (Part 21 and 50.55(e)) reports. It is the opinion of the Board, based on the results of the review, that L -strong measures are required by the licensee to provide adequate assurance that previously completed safety-related work was properly accomplished and i - that current and future work is adequately controlled. Escalated enforce-t - ment action consistent with NRC pnlicy should be effected to assure that the licensee takes the necessary corrective action. The WNP-2 enforcement . package currently under review at NRC headquarters is the recommended escalated action to be taken. In addition, it ic the opinion of the Board that NRC:RV inspection efforts should be increased in the areas of quality' assurance, management, training, safety-related strtctures, pipe supports, electrical l equipment, electrical (trays and wires), und instrumentation. 4 O e \\ g5 ,, 90 /(L h0 l vg l P 1

V 6; S. Spencer' ' Licensee actio'ns related to IE Bulletins, Circulars, and licensee event repoits were generally satisfactory. No spe.cific change in licensee programs or NRC. inspections in these areas is recommended at this time. 2 3 Regional Review Board Members: ( R. T. Dodds, Chief, Engineering Support Section ( I.WIh3. e,O ~ T. W. Bishop, Reactor Inspector 0 ' O. F. Kirsch, Reactor Inspector h J. D. Carlson, Reactor Inspector [ Sy Ni w i P.'H.' Johnson, Reactor Inspector U

Enclosure:

WNP-2 Evaluation form - for Appraisal Period 4/79-4/80 o y 4 e O c

A.- Number and Nature of Noncomoliance: Items Noncon.pliance category: Unit 1 Unit 2 Unit 3-Violations 1 Infractions '27 Deficiencies 5 Areas of Noncompliance: Unit 1 Unit 2 Unit 3 '(ListAreasasRequired)' (Points) (Points) (Points) n (see ' Attachment 1) 100 x 1 = 100 27 x 10= 270 Total Points 370= B. Number and Nature of Deficiency Reports (seeAttachment1) C. Escalated Enforcement Actions Civil Penalties Currently under HQ review Orders - NONE v Immediate Action Letters 1) 11/21/79: SSW-stop work pending NRC review of corrective action - still in effect 2) 11/21/79: PWR-stop work pending NRC review of corrective action - lifted 2/8/80 4

?y D. Management Conferences Held During Past Twelve Months Evaluation of WPPSS performance related to construction presented to WPPSS management on 4/24/79 and documented in IE Inspection Report No. 50-397/79-03, (Attachment 2). The WPPSS' reply is provided in WPPSS Letter G02-79-100, of 5/18/79 (Attachment 3). E. Justification of Evaluations of Functional Areas Ostegorized as Reouiring an Increase in Inspection Frequency / Scope Th0 routine programmatic inspection requirements for WNP-2 are nearly , fulfilled.. However, the extensions of the construction completion date. concerns with previously completed safety related work, and concerns with the licensee's handling of current construction activities warrant increased NRC inspection in several areas. Detailed justification for increased inspection frequency is provided in Attachment 7. Areas of increased inspection are summarized below: . Quality Assurance, Management, Training - Concerns exist 'with the '1. acceptability of previous work; licensee's ability to control current activities including improving timeliness for identification and response to problems, thoroughness of evaluations, and training / problem feedback to personnel. 2. Safety-related structures - Followup on repairs to the sacrificial shield wall and (licensee identified) problems associated with current wet-well structural activities. 3. Piping & Hangers - Followup on current problems of pipe supports and pipe whip restraints. 4. Electrical Equipment, Electrical (Tray & Wire), and Instrumentation - Concerns with electrical separation, equipment qualification, and quality cla,sification of electrical components. G e

r EVALUATION SHEET-RECOMMENDED CHANGES ~ IN INSPECTION FREQUENCY / SCOPE Inspection Frecuency and/or Scooe FUNCTIONAL AREA 2 : In'crea se No. Change Decreas-l '1.. Quality Assurance, Management & Training l X, l l

2. ~ Substructure & Foundations X (1) 3.: Concrete X (1)

Liner (Containmenh.&Others) X (1) 4. 5. Safety-Related Structures X 6. Piping & Hangers (Reactor Coolant X I & Others) 7. Safety-Re[atedComponents(Vessel, Internals & HVAC) l X (1) p 8. Electrica1' Equipment { X l { l l 9. Electrical (Tray & Wire) X Id. Instrumentation X 11. Fire Protection .l f x ()) j 12. Preservice Inspecticn l l x (3) [ 13. Reporting (2.) X (1) 1 1 ] t I j i

i..

~ i i r-NOTES: (1) Status of constructio'n and Licensee's e performance does not warrant any change in programmatic inspection frequency. (Des'ignated* Regional Manager) (2) Licensee reporting and followup to g/g/fd i Bulletins, Circulars,and50.55(e)- items is satisfactory, Licensee Date action is summarized in Attachments 4, 5 and 6. +~v

'l _i. f I REGION y ACTION PLAN Facility - Washington Naclear Project No. 2 (WNP-2) Appraisal Date May 7,1E ~ 1.. Es'calated Enforcement Action Based on concerns associated with the sacrificial shield wall, pipe whip restraints, and other recent construction activities, escalated enforcement action has been initiated. The enforcement action includes a civil penalty and specifies specific licensee actions which are expected. Ratic~nale. for the p'roposed licensee action is provided in Table A att' ached. 2. Inspection Program Changes (include increased or decreased frecuency) Increased-inspection effort is to be initiated in the areas of Duality Assurance, management, training, safety related structures, pipe supports, electrical equipment, electrical -(trays and wire), and instrumentation. Rationale for the-increases is provided in Table A. ~. (/f[J 3. Management Meetings Planned . A meeting with Licensee management is scheduled for May 20, 1980 at the Licensee's Headquarters in Richland, Washington. '4. Status of Action From Previous Appraisals While the licensee has,taken action on NRC comments from previous appraisals these actions have not been wholly effective. Accordingly, the escalated enforcemt..t action has boca proposed and increase inspection effort is to be initiated. 4 T 4 Regional Director s -~-

~ . TABLE A JFsN1{f 5: WNP-2 ACTION PLAN: ~ ' '5 CONCERN EXAMPLES PROPOSED ACTION-1. Questions exist in the -The sacrificial' shield wall, completed Require licensee to perform:, +% ^ acceptability-of completed-in' June, 1978 has been found to be safety related work. seriously deficient, indicating quality An-independent review of completed safetye ~ controls during the period of fabrica - related work accomplished by those' con-tion and erection were nbt as effective ~ tractors not having an NRC approved quality. .s as required. (IE Inspection Report (s) assurance program to determine.whetherLthe- . 50-397/79-12, 13, 16, 80-04) quality assurance program was; adequate'to. ? assure such work was properly performed. The The pipe whip restraints, completed -depth of review should be cosmienisurate with in Februa_f. 1977.have been found to be .the safety function of the structges,' system ae-Iously deficient, indicating quality or components.and-should. include: sontrols during this period were not as effective as required. (IE Ir.spection

a.. Examination of the quality pro <.edures Report (s) 50-397/79-06, 80-04) cand specifications applied to the. work.

The postueld' heat treatment-of pipe welds

b. Review of the qualifications of the-conducted during the period of February.-

personnel who performed and inspected. 1977 to 1979 was found to be seriously: the work. deficient, indicating quality controls I. during this period werc not as effective

c. Review of all dispositions of noncon-..

as required.- (IE Inspec ion Report (s) formance reports,' design changes, field. ] 50-397/79-10) change reques'es, and information requests The pipe support installation / inspection

d. Review of quality records associated j

prograr up to May,1978 was found to be with the work. seriously deficient and was the subject of 9 items of noncompliance during Dec 1977-

e. Reinspection, to the degree warranted, fs May 1978, indicating prior quality controls verification that records accurately refl; were not effective.

(IE Inspection Report (s) the installed conditio4 of the work. 50-397/77-07, 78-03, 80-06). f.Identificationofrepairaoffurtheractk HVAC installation (including safety related to be taken for those structures systems,l j portions) up through 1978 was found by or components which are found to be the licensee to be sufficiently deficient to-deficient or. questionable,'as a result of require a 100% reinspection. (IE Inspection the review. Report (s) 79-04) ^

and, In 1978, the licensee found piping con-tractor welding procedures to have non-traceable test results and other probicas' r e iring "re-qualification" of all pro-ccduren.

(IE Innpection Heport(n) 79-14, 79-16)

Pg. '2 cf ~ 5 - f OI .=- j ' CONCERN EXAMPLES-PROPOSED-ACTION; g ,~ ~ RequiretheLlicenseetoheviewitheihro~ gram for conducting, inspections ande evaluation of_ test'results.during testig pregrams-(including construction,: preop-erational, and power testing. programs) toassuretheadequacyof-construction $ safety-related systems. ' s 4 i* Increase NRC inspection frequency'for - Quality, Assurance.and Management, safety related structures, and pipe hangers.. 12. Licensee control of Pipe support installation, the subject Require licensee to perform: current work activities. of 5 items of noncompliance in 1977, (This concern is further 4 items of noncompliance in 197E, 1 itew An independent review of the WNP-2 "projci defined in items 3, 4, of noncompliance in 1979, is again management, construction, engineering, and 5 below). the subject of an item of noncompliance and quality assurance programs'and organ' in 1980. (IE Inspection _ Report (s) izations to ascertain their adequacy-to 50-397/77-07, 78-03, 79-03, 80-04). exercise control over the quality aspects of current and future constructi Ability to maintain component and activities. ~ equipment cicanliness continues to be a problem site management has not been increase NRC' inspection frequency for. 'i effective in resolving. Cleanliness pipe supports and cleanliness. was the subject of 4 items of noncom-pliance in 1979 and one in.1980. (IE Inspection Report (s) 50-397/79-01, 79-04, 79-16, 80-04) i (for gdditional examples refer to items 3 and 4.below). 1 \\ t 4 --r

Pg 3 f5 CONCERN EXAMPLES PROPOSED ACTION 3. Timeliness of identifica-NRC identified a concern on the scismic Require the licensee to review: tion of problems to site qualification of electrical conduit and licensee headquarters clamping devices in October 1978. As of The system for assuring corporate manag, management, and timeliness April 1980, the licensee has still not ment's awareness of site prob 1 cms on a of response to problems. detenained which clamping devices will timely basis, including management inpu perform to seismic requirements. Some into the evaluation and correction of steps were taken in January 1980 and these problems. .s April 1980 to restrict the type of clamping device to those which show the Increase NRC inspection frequency fo'r most promise in meeting seismic testing management, electrical equipment, requirements; however, many devices electrical trap and wiring, and installed between 10/78 and 1/80 may instrumentation. require reinspection / replacement. (IE Inspection Report (s) 50-397/78-10, 78-11, 79-04, 79-09, 80-07) Electrical separation requirements has been an NRC concern since October 1978. The licensee's requirements in this area have been changed by the licensee but were not formally submitted to.RR as of April 18, 1980. The latest set of requirements do not appear to comply with current industry standards and have the potential for resulting in significant rework if disapproved by NRR. NRC:RV concerns with the new criteria have been forwarded to IE:llQ for submittal to NRR. Environmental qualification of electrical components has been an NRC concern since March 1979. While the licensee has been active in this area the actions have not been completed. (IE Inspection Report (s) 50-397/79-04). In August 1979, the NRC pointed out an inconsistency between the PSAR and the 215 contractors inspector qualification pro-cedure. As.of February 1980, no effective action had been taken. (IE Inspection Report (s) 50-397/79-14, 30-04).

CONCERN' EXAMPLES- ' PROPOSED ACTION. [ 4.. Thoroughness in'per-Licensee management was advised by tneir. Requ' ire the licensee to,revievi- ' - forming evaluations of contractor of problems with the sacri- -problems. 'ficial shield wall in November, 1978. A' The mechanism for assuring identificatiG corrective acti.on plan was developed and- ~ d thorough evaluation.of. construction. an implemented in March, 1979..In June, . deficiencies, including'actionsto,assuq 1979, the NRC received allegations related areas are not similarly deficien concerning the wall. Investigation at-that time established that validity of Increase NRC inspection frequency in Leckenby sacrificial shield wall' records -Quality Assurance and..Managenent. was.in question (a thorough licensee evaluation during November, 1978 to March, 1979 should have 14entified.this concern).. In July, 1979, the licensee's corrective action program was expanded to include a quality review of the Leckenby program. This review was effec-tively completed by November 30, 1979 without identifying significant problems, in Leckenby QA program, which were identified by the NRC investigation of 11/27/79 to 2/28/80. In addition, in October, 2979, the NRC identified that licensee's engineering review for struc-tural acceptability of the wall (which started in March, 1979) was being performed on an incomplete data base (engineers were plotting / extrapolating typical wall defects in lieu of all actual known defects) (IE Inspection Reports 50-397/ 79-12, 79-13, 79-16, 80-04) Licensee reported major defects in Leckenby electroslag welds for certain pipe whip restraint brackets in a 50.55(c) item in March, 1979. Of the 45 brackets fabri, cated, 20 had to be completely rebuilt, 14 were repaired, and 11 were found g acceptable. The licensee's evaluation of i the problem failed to address other elector-slag welding cione by the sime contractor for WNP-2 sacrificial sbi31d weil ano pipe whip restraints) which turned out to have ,m

Pg. 5 cf 5 : CONCERN EXAMPLES PROPOSED ACTION .? significant welding deficiencies as well as major quality prob 1 cms. A._ thorough cvaluation should have surfaced many of-the Leckenby problems later identified-by the NRC. (IE Inspection Report (s). 50-397/79-06,'79-12, 79-13, 79-16, 80-04), g 3. Although the licensee has Refer to item 2 above for examples. Require the licensee to review: made significang improve-ments in training with their The system to assure adequate _ training.0 Q-tips program, further all levels of construction personnel-in improvement is warranted in the.need and importance'of satisfying. the licensee's program for quality requirements and to encourage a( personnel training and personnel to communicate, without problem feedback in, view of-recrimination on the part of the licens the repetitive nature of or its contractors, their. concerns or several items of noncom-knowledge of improper construction-pliance during the past practices to proper levels of managemenG year. for evaluation and resolution. 9 Increase inspection frequency in Qualitt Assurance, management, and' training. e 5 a

x-ITEMS OF NONCOMPLIANCE ITEM NUMBER TYPE LTR DATE REPLY LTR. NO. REPLY DATE CORRECTIVE ACTION / STATUS 1

79/04/03 I

04/17/79 G02-79-92 05/10/79 (Failure to maintain clea- ~ JCI) Ineffective (See12 2 79-04/04 I 04/17/79. G02-79-92 05/10/79 (Failure to monitor weld preheat) Satisfactory-cict 3 79-04/05 D 04/17/79 G02-79-92 -05/10/79 (Failure to maintain insp. status) Satisfactory-clos '4 79-04/08 D 04/17/79 G02-79-92 e 05/10/79 (Failure to prop. code els cables) Satisfactory-clos 5 79-04/11 I 04/17/79 G02-79-92 05/10/79 (Failure to prop. install, batt. racks) Satisfactor;. working 6 79/04/1,2 D 04/17/79 G02-79-92 05/10/79 (Failure to prop. ident. e bkrs) Satisfactory-close: 7~ 79-10/01 1 01/21/80 G02-80-55 03/05/80 (Failure to qual. PWHT proced.) Reply insufficier 8 79-10/02 I 01/21/80 G02-80-55 03/05/80 (Failure to provide procee for h!HT eq.)Satisfactor;. l working 9 79-10/03 D 01/21/80 G02-80-55 03/05/80 (Failure to maint records PWHT) Satisfactory-workin. 10 79-10/04 I 01/21/80 G02-80-55 03/05/80 (Failure to PWHT per ASME Code) Satisfactory - work-11 79-16/06 I 12/18/79 G02-80-30 02/04/80 (Failure to maint sys cle: F/L) Ineffective-(See15) 12 79-16/08 I 12/1'8/79 G02-80-30 02/04/80 (Failure to maint sys cle: JCI-Repeat) Ineffective (See15) 13 '79-16/09 I 12/18/79 G02-80-30 02/04/80 (Failure to provide cl. I-equip. for RPS) Evaluati: in Progress 14 79-12/04 V 06/17/80 (Failure to prop weld SSW 15 79-16/06 I 06/17/80 (Failure to main. sys, cleanli F/L & JC1)-Repeat 16 80-04/01 I 06/17/80 (Failure to prov. SSW UT (proced.) t-17 80-04/02 I 06/17/80 Failure to prov. PWR UT proced.) 18 80-04/04 I 06/17/80 (Failure to prov SSW strai l proced) 19, 80-04/05 I, 06/17/80 (Failure to prov PWR stra" (proced) Failure to prov SSW welo-20 80-04/06 I 06/17/80 seq. Procec.) 21 80-04/07 I 06/17/80 (Insuff SSW records ident, of Insp. personnel) 22 80-04/16 1 06/17/80 (Insuff. SSW records ince information) 23 80-04/08 I 06/17/80 (Insuff. PWR records - in of insp personnel) 24 ' 80-04/17 I 06/17/80 (Insuff. PUR records - inconsist N0E rpts) 25 80-04/18 I 06/17/80 (Insuff PWR records - incerrect insp. ident.) mee

f'.a ~ ITEMS OF NONCOMPLIANCE (cont.) ITEM' HUMBER TYPE LTR DATE REPLY LTR. NO. REPLY DATE CORRECTIVE ACTI0ll/ STATUS 26- 04/18-I 06/17/80-(Insuff PWR records.- incorrect insp. ident.) 27 80-04/09 I 06/17/89 (Failure to qual PWR ins. personnel) 28 80-04/10 I 06/17/80 (Failure to qual SSW ins: personnel) - 29 80-01/02 I 06/17/80 (Failure to control weld fill,mati.) 30 80-04/12 I 06/17/80 (Failure to repair per A' 31 80-04/13 I 06/17/80 (Failure to prop. UT PWRt 32 80/04/14 I 06/17/80. (Failure to prop insp. pipe supp.) ' 33 80-04/15 0 06/17/80 (Failure to doc. weld ins V =. VIOLATION 9 I = INFRACTION O = DEFICIENCY l 4 k 9 e 9 4 9 e. O c

- a _. bh ^ ^ ' ' 'o,, UNITED STATES 8 }' *.f

UNV'y'r g NUCLEAR REGULATOP.Y COMMISSION

/ e e REGION V \\ 1000 N. CA'.lFORrJf A DOULEVA AD 9 p SulTE 202. WALNUT CREE K PLA7A s,,,e WALNUT CREEK. CALIFOMJf A 9'506 May 25,1979 Docket No. 50-397 Washington Public Power Supply System ~' P. O. Box 958 Richland, Washington 99352 Attention: Mr. 11. O. Strand Managing Director Gentlemen:

Subject:

NRC Inspection at Washington Nuclear Project No. 2 (WNP-2) This refers to the inspection conducted by Messrs. T. W. Bishop and r._ P. P. Marbut of this office on April 23-26, 1979 of activities authorized by I;P.C Construction Permit No. CPPR-93, and to the discussion of our fi ings. held by Mr. Bishop with Mr. D. l.. Renberger 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, inter-views with personnel, and observations by the inspectors. No items of noncomplianc'e with HRC requirements viere identified within the scope of this inspection. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the encloseI! inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The applica-tion must include a full statement of the reasons why it is claimed that the inforcation is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure J , h c, b,/ , G:. E hi i _p p ' /,/ ,i ( G V ,f ( ,/ p?? t fg Ace 4 ML'UI 5.

4 Washington Public Pcwer Supply System May 25, 1979 j % Y to the application,.since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you ' in this regard within the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will'be glad to discuss them with you., Sincerely, ff { ! s G. S. Spencer, Chief Reactor Construction and Engineering Support Branch

Enclosure:

~

IE Inspection' Report No. 50-397/79-08 cc w/o enclosure: M. E. Witherspoon, Division Manager Quality Assurance, WPPSS

O.

A. D. Kohler, Manager M-WUP-2 Project r. de e O e

) ~ U

s. NUCLEAR REcVLATORY,, COMMISSION OFFICE oF ins?icTION AND Eh70RCEF.Eh7

.s, REGION V R;p:rt No. 50-397/79-08 4 DockN:No. 50497 treense No. CPPR-93 safeguards croup Lican:ee: 11ashington Public Power Supply System P. 0. Box 968 Richland, Washin'gton 99352

- Fccility Narne:

Washington fluclear Project flo. 2 (WHP-2) Insp2ction at: WilP-2 site Benton County, Washington . Imp ction pr. ducted:_ % il 23-26, 1979 fd h!I[Y !71 Insp;ctors: T. W. Bishop, React'd Inspector ' ' Da t'e 's i gned t.'5/7$ C% P. P. Ilarbut, Reactor Inspector Date signed Apprcved.By: Mn p R. C. Haynes, Chief, Pr*ojects Section, Reactor Ddte si'sned Construction and Engineering Support Branch surem$ry: ' Inspection on April 23-26, 1979 (Report No. 50-397/79-08) Areas Inspected: Routine, unannounced inspection by regional based -inspectors of constructipn activities including: observations of safety-related piping work and review of quality records; reactor re-circulation nozzle modifications - review of quality implementing procedures, observations of work activities, review of quality records; reactor vessel protectio.n and preservation - review of quality pro-cedures, observations of work, and review of quality records; and followup on previous inspection findings. The inspection involved 54 t inspector-hours onsite by two ilRC inspectors. Results: fio items of nonccmpliance or deviations were identified. RV Form 719 (.~ 7467h55@

~~ f ~] DETAILS _ 1. Persons Contacted- ' Washington Public Power Supply System (UPPSS) +*D.L.Renberger,AssistantDirectior,Technoloci +*A. D. Kohler, H!i?-2 Project Manager +*J. Janus, Construction Manager +M. E. Witherspoon Division Manager Quality Assurance +*A. M. Sastry, WNP-2 Project Quality Assurance Manager

• C. R. Edwards, Manager, Vendors / Audits
• J. H. Steidl, Sr. Quality Assurance Engineer D. C. Timmons, Project Engineer, WNP-2 F. R. Ozment, Sr. Maintenance Engineer-G. I. Wells, Construction Specialist
• H. F. Sullivan, Sr.~ Quality Assurance Engineer Burns & Roe, Inc. (B/R)_
• W. P. Rausch, Quality Assurance Director
• R. C. Root, Deputy Project Manager
• G. T. Harper, Jr., Manager, Technical Support
• H. J. Parise, Deputy Project Quality Assurance Manager P. Massman, Sr. Quality Assurance Engineer, Electrical Fischback/ Lord J. Collins, Quality Assurance Manager H5H/Boecon/Bovee and Crail/GERI L. Ramsett, Corporate Quality Assurance Manager A. Larson, Quality Assurance Manager L. Buckner, Quality control Supervisor P. Young, Quality Control Inspection Supervisor R. Taron, Quality Control Inspection Supervisor General Electric Installation and Service Engineering (GE/IP,SE)

V.'Losiuk, Site Manager W. Pcppin, QC Supervisor + Denotes those present at management meeting on April 24, 1979.

• ' enotes those prese;e. at exit interview on April 26, 1979, J

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_ __ _ ^ .o ' /~g 2., , Construction Status Licensee representative.s reported that the construction of WiiP-2 was f6.; complete as of April 20, 1979. ~ icensee Action on Previous Inscection Findinos, 3. L a. (0 pen) !!oncompliance (50-397/79-01/01): Piping system clean-liness was not maintained. ~ The licensee's response to the item of noncompliance was suninarized in WPPSS' letter flo. G02-79-28 of February 22, 1979. With the exception of the revision to Work Procedure lio. 5.9, all actions identified in the letter were verified during a previous inspection.' Work Procedure ilo. 59, Revision 6, entitled " Cleanliness Program and Control Procedure" and its . implementation were examined during the current inspection. The inspection of six partially welded joints and three capped pipes revealed that, in general, cleanliness is being controlled in accordance with WP-59. It was noted, however, that some of the requirements of WP-59 for controlling material which is temporarily left inside equipment have not been fully imple-mented. The inspector observed a tag indicating temporary material was inside the pipe, yet this condition was not noted on the appropriate weld record form as required by the procedure. In addition, the procedure refers to the use of a " Temporary a. Material L.,." Contractor representatives stated that it was 2 their-understanding that the requirement for the log had been deleted, accordingly no such log had been developed for piping inside the containment. Licensee representatives stated that the control of temporary material would be reviewed and appro. priate action taken. This item will remin open pending full implementation of WP-59 and will be re-examined during a subsequent inspection. b. (0 pen) Followup item (50-397/78-10/07): Equipment maintenance inspection record forms are inconsistent with corresponding procedures. The licensee has implemented the revised equipment maintenance inspection program defined in Work Procedure flo. WP-106. The programatic aspects of the revised program were examined during a previous inspection and were found satisfactory. Implementation of the program was examined during the current inspection. A sample of five recently inspected pumps and the a'ssociated inspection records were examined. It was noted that two of the pumps (reactor recirculation pumps P.RC-P-1 A and 10) had not yet been incorporated into the WP-106 program. The pumps were being inspected under the old maintenance program. Licensee representatives stated that the WilP-2 plant i

7 1, ' equipment llst would be comparoc.! to the Up-105 equipment L, caintenance list to assure all equipment is incorporated into the new paintenance program. Inspection of the five' pumps selected ident'ified that the protective covers of th:. two RRC pumps had been torn and debris had accumulated on the pumps. The remaining three pumps were found to be in a satisfactory condition. While the damaged RRC pump covers were replaced prior to the end of the current inspection, it is noted.that-addit _ional efforts are required to assure all' critical com-ponents are included in the maintenance pogram and components are maintained in a clean and protected fashion as required by the maintenance program. during a subsequent inspection.This item will be further examined (closed) Followup item (50-397/70-10/08): c. Possible concrete -voids in the sacrificial shield wall. The licensee has approved a project change notice (PCN 6641) which provides for the investigation of the sacrificial shield wall.for voids. The approval (provided in UPpSS letter WPB?,- 79-165 of April 13,1979) investigating for voids in concrete will consist of exam-states that ination during startup and/or operat core 'as a neutron and-gamma source. icn, using the reactor This investigation will be carried out in two stages, as follows: ' [" (1) Initially, neutron detection devices will be placed at selected locations in the drywell to detect possible neutron streaming near vulnerable safety-related equip-ment, and to measure general neutron flux levels during operation. These devices will be retrieved and examined when the reactor is shut down, and an evr.luation then modo regarding whether or not excessive voids exist. it is determined that excessive voids exist, gamma detectors If will be used with the fission products in the core as a source to pinpoint the location of the voids. Corrective measures will then be taken. when the reactor is shut down.All this will take place (2) Inot it is possible for permissiblThe licensee has direc 3 e radiation dose rates for safety-related equipment to be exceeded during a single refueling cycle (assuming worst-case voids were present). If so, then an examination will be made prior to startup of those areas where void formation is likely, and where adjacent safety-related vulnerable equipment is located. Such examination, if required, would most lihely consist of drilling or cutting through the skin plate. L

j- - It appears that the action being taken by the licensee is sufficient to identify and correct any excessive voids in the sacrificial shield viali. The inspector has no further questions on this matter at this time. d. (Closed) Followup item (50-397/79-04/06): Electrical contractor's calibration procedure did not clearly specify evaluation or documentation requirements for equipment found out of calibration. The contractor has consolidated procedures CP-801 and QAP-801 into CP/QCP-801, Revision 0A, entitled " Calibration and Certifi-ca tion of Tools Inspection and Test Equipment." The new procedure was examined and found to be consistent with PSAR, specification, and 10 CFR 50 Appendix B requirements. The ~ procedure requires the issvence of an inspection report (IR) or a nonconformance report (i!CR) if equipment is received for calibration in an out-of-tolerance condition. An evaluation of the previous use of the equipment is to be made and docu-mented in the IR/flCR. The inspector examined recent calibration data and verified that appropriate evaluations and documentation had been made. This item is closed. e. (0 pen) Followup item (50-397/79-04/09): Inadequate hydraulic cable crimping tool calibration procedure and documentation.

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The TMB-15 hydraulic crimping tool calibration procedure has been recently revised by the tool manufacturer. The manufacturer's recomendations have incorporated into a revision of the electrical contractors Calibration Precedure ilo. TI-2. The revised procedure was in the review circuit at the time of the current inspection. This item will remain open pending issuance and. verification of implementation of the revised procedure. f. (Closed) Unresolved item (50-397/79-04/10): 480 Volt circuit breakers of different quality classes may be interchangeable. Licensee investigation has established that all Uestinghouse 480 volt circuit breakers were designed, fabricated, and tested to seismic and quality class I requirements, although their service at WNP-2 may be either quality class I or class III Ilowever, since breakers of different quality classes may be subjected to different handling requirements over the 40-year life of the plant, the licensee has initiated action to n:odify those breakers which perform quality class I service. The n:odification, which will be accomplished in accordance uith engineering directive PED-W218-E-1457, will change an interference bracket to preclude interchangeability of breakers of different quality classes. The inspector reviewed the results of the licensee's investigation and the engineering directive. The action taken by the licensee was found to be consistent with PSAR and specification requirements. The inspector has no further questions on this item. .Q

~ r '4. _ Reactor Pres'sure Boundary and Other S'afety-Related Piping (Welding) a. Observations of Work and Work Activities The inspector examined inprocess and completed work associated with 22 weld joints. The welds and associated activities were examined for compliance to the requirements of the applicable welding procedure specification, Section III of the ASME code, and the PSAR.. Of the 22 welds examined 3 were 26" mainsteam H piping (HS-530-1.3 series), 3 were 12." reactor feedwater piping-(RFU-419-8.9 #2, 2A, 3), 2 were reactor water cleanup piping (RUCU-818-5.7 iBA, RUCU-818-3.4, !2), and 14 were 1" reactor core isolation cooling piping (RCIC-665-4.9 series). 'The welding activities were examined for vield fit-up 'and cleanliness (where accessible), identification, location, size,-appearance, interpass temperature control UPS compliance - use of specified filler metals and evidence of QC verifications. The welding activities viere found to be properly controlled and in compliance with all requirements. Ho items of non-compliance or deviations were identified. b. Review of Quality Records '( %l The inspector examined inprocess records associated with the above welds'. The records included UPS qualification records, Iwelder qualification records, material certifications and test reports, weld inspection records, weld filler material with- _drawal slips, and HDE records. No items of noncompliance or deviations were identified. 5. Reactor Recirculation Inlet Hozzle Safe End Replacement In order to improve plant reliability, the licensee has initiated action to replace the existing Inconel recirculation inlet nozzle safe enes. The current design of the safe ends creates a crevice condition at the thermal sleeve attachment. The replacement safe ends wfll' be of 316L material and a " tuning fork" design. The new design is intended to preclude the intergranular stress corrosion cracking phencmenon associated with Inconel and a crevice geometry. j a. Review of Quality Assurance Irnolementing Procedures The inspector examined the specifications and licensee im-plementing procedures for the reactor recirculation inlet' nozzle safe end replacement program to determine compliance to the re'luirements of the ASME B&PV Code and Regulatory Guide 1.44, Control of the Use of Sensitized Steel. mm

The fol' lowing procedures viere examined: (1) Gt Specification 22A6643AD, Revision 0.. February 27, 1979, Reactor Vessel Recirculation Inlet Nozzle -(2) GE Specification 21A2039, ' Revision 1, January 10, 1974, lleid Metal Ir.terfaced Location (3) GE Specification 21A2040, Revision 0, January 11, 1974, Cleaning and Cleanliness Control for Field Modifications of Vessel Components (4) GE Field Disposition Instruction 61/113050, Revision 0 March 9,1979. RPV Recirculation Nezzles (5) t!PPSS Procedure SEM-1 Recircula

• Safe End Modifications, Revision 0, March 8, 1979 (6) l!PPSS Procedure SEM 2 Installation of Temporary Supports /

Restraints on Recirculation System, Revision 0, March 6, 1979 (7) LlPPSS Procedure SEM-3, Revision 0, Installation of Temporary Restraints for Jet Pump Risers, March 29, 1979 (3) l!PPSS Procedure'SEM-4, Revision 0, Machining Sequence for Disassembly of Recirculation ilozzles, March 7,1979 (9) llPPSS Procedure SEM-5.. Revision 0 Position Monitoring of Recirculation Piping Syctem and det Pump Risers, March 29, ~ 1979 (10) llPPSS Procedure SEM-6 Installation of Replacement Com-ponents and Closure Spools, April 16, 1979 (11) Power Cutting Inc Procedure PCI-l Machining Procedure for

, Removal of Closure Spools e

(12) Power Cutting Inc Procedure PCI-2 Machining Procedure for External I! eld Preparations, Revision 0 (13) Power Cutting Inc Procedure PCI-3 Macnining Procedure for Removing Safe End Extension from Cicsure Spools, Revision 0 (14) tJPPSS ISI/l!DE Instruction QCS&I-077, Revision 0, Feb'ruary 20, 1979, Instruction for Ultrasonic Thickness Measurement and tl eld 1.ocation

7 v + }lhile no items of noncompliance or deviations were identified, the fol. lowing items were noted:. (1) The specification instructions (FDI 61/113060) require that the recirculation pump discharge line be blocked when performing the cut on the vertical recirculation riser to prevent machining chips from falling in the pump discharge line. The licensee's implementing procedure (SEM-4, Disassembly Sequence) does not require blocking the discharge line but instead requires the final parting to be done by grinder which precludes chips but does not preclude grinding dust and grinder particles. The licensee representatives stated that they would evaluate the use of a single wheel pipe cutter or similar device' to pre-clude the entry of grinding particles. (2) Because of the sensitivity of safe ends to chemical con-taminants, the specifications for safe end replacement have specific recommended controls on cleaning and the control of' the chemical content of miscellaneous materials such as tape, grinding wheels, penetrants, etc. The licensee's local implementing procedures, however, provide nondefinitive instructions such as " clean" (after machining the weld bevel preparation) and do not invoke special contaminant controls. Licensee representatives stated that the procedures fer cutting and preparation f. welding t;ould be revised to be specific in regards to cleaning methods. Addi tionally, licensee represen.atives stated that action would be taken to resolve the method of control of miscellaneous materials. (3) The procedure for reassembly of the safe ends (SEM-6) requires quality control personnel to check the fitup of the thermal sleeve to ensure it is parallel and concentric to the safe end. Ho quantitative values are given for paralleli'sm or concentricity. Licensee representatives stated that the procedure would be revised to' provide quantitative values. (4) The reassembly procedure (SEM-6) uses a pipe dam for , cleanliness control during pipe weld bevel preparation. r Af ter dam removal the procedure requires that quality control personnel verify cleanliness.- The method and scupe of the cleanliness verification was not clearly identified in the procedure. Licensee representatives stated that the procedure would be revised to require an inspection of the piping in the horizontal run below the vertical recirculation risers by use of a borescope or scme other remote visual means to provide greater assurance of cleanliness of the system prior to closure. ~ ,1

.g. b. Observation of Work and Work Acti'[ities '( The ir.spector examined the preparations for cutting of the recirculation inlet piping. The observations included in-spection of the bracing installed on both the.inside and the outside of the reactor vessel, and the cutting machine set-up. ~ The inspector also reviewed precutt,ng activities with cognizant licensee and contractor representatives. The activities were examined for compliance to the approved procedures identified in Paragraph 5.~a. While no items of noncompliance or deviations .were identified the following items were noted: (1) The licensee procedure for locating weld centerlines (SEli-1) required chemical etching of the reactor vessel nozz'e welds to establish the Inconel to carbon steel in+.erfaces as reference points 'for cutting locations. Licensee representatives stated that the etching had not been done on all nozzles because the interface between the carbon steel and Inconel was visually apparent without etching. While this action is technicalli acceptable, there was no documentation issued which formally approved the deletion of the etching require-ment. The inspector expressed concern regarding the ?. deviation from procedures without written authorization. ~ Licensee representatives stated that action would be taken to make sure that cognizant personnel understand (7 the necessity for strict compliance with all requirements of the procedures. (2) The cutting machine to be used for cutting through the safe end and thermal sleeve was installed on a safe end in preparation for cutting. The nachine was observed to be installed such that the exis of the machine was at about 5 of misaligr. ment with the axis of the safe end. This was apparently due to the safe end aiid safe end extension having different outer diameters whereas the machine i;s designed to be installed on a single diameter pipe spool. The cutting mechanic intended to resolve the problem by moving the machine back to the smaller diameter pipe and cutting a groove in the larger diameter safe end to provide a track for the cutting machine front roller I wheels, then m' ving the machine forward so that the front o set of roller wheels would ride in the track. The track was intended to be deep enough to bring the axis of the cutting machine into aligr. ment with the axis of the safe end. The cutting procedure SEM-4 did not recognize these additional procedural steps. Licensee representatives i stated that the procedure would be revised, prior to commencing cutting, to recognize the additional cutting steps. e 0

u. -- y j - p c. Review ~of Quality Records Tha inspector 'excmined quality record associated with nozzle thickness testing (for conformance to procedure QCSEI-077) and co:r.pleted data sheets for reactor recirculation piping posi-tioning (for conformance to the requireaants of' procedure SEM-5). Ilhile no items of nonccapliance or deviations were identified, the following items were noted: '(1) The. inspector observed that on eight of the ten nozzles, the wall thickness measurement data sheets did not show the ultrasonic instrument serial number, tranducer ser.ial number and calibration block serial number as required by the procedure. This was not considered an item of non-compliance since the procedure was an informational type and had no safety significance. Licensee repre-sentatives stated however that the UT instrumentation data would be obtained and documented. .(2) The safe and replacement specifi;ations require Nuclear Steam Systems Supplier (GE) approval for any cutting fluids used. The licensee is intending to use "Cimperial 10" cutting fluid. Records approving the use of this / fluid were not available at the !! iip-2 site. Licensee-representatives stated that written GE approval would be obtained. The licensee's actions to resolve the procedure concerns noted in paragraoh 5.a and b, and assure that personnel are cware of procedure compliance responsibilities will bi examined during a subsequent inspection (50-397/79-08/01). 6. Peactor Vessel Intetrnals a. Review of Quality Assurance Implementing Procedure The quality assurance implementing procedtfre relating to the pcotection and cleanliness preservation of reactor vessel irite'rnals was reviewed. The procedure (GE/1&SE No. IV-E-201, Revision 2, entitled "RPV Access and Cleanliness Procedure") was found to be in compliance with PcAR and contract specification requirements. No items of noncompliants or deviations were identified. b. Observations of Work and Work Activities The protection and cleanliness preservation of the installed reactor vessel internals were examined. The examination incio. led observations of access control, physical protection and blanking of vessel openings, equipment protection and A__

,W cleinliness control related to 3:ork activities within' the i L vessel, and compliance to procedure IV-E-201'. lio items of noncompliance or deviations were identified. c. P,eview of (Uclity Records ~ The inspector examine <' records of access coritrol and system-cleanliness surveillarces. No. items of noncompliance or deviations were identified. - 7. Manacement fleetings a'. General Evaluation of-Recent Ccnstruction Activities A meeting was held on-5pril 24._1979 with licensee repre-sentatives denoted in Paragraph 1. The inspector presented a - general evaluation of recent construction activities at the vidual contractors' pector expressed concern that some indi-activitie WNP-2 site. The ins and effective reanner at this advanced state of construction. Specific areas _which require immeciate improvement were' reviewed. These were: excessive time required to correct identified deficiencies; control of work activities of contracters having 'known quality problems; control of quality records at~ the contractors level; and large inspection backlogs. The inspector f'..

discussed the need to adequately preplan quality class I work activities and assure first line personnel are aware.of their s

responsibility and accountability for strict plan and procedure compliance. Licensee representatives were responsive and stated that immediate actions wo0Td be initiated to address r. the concerns identified. The licensee stated that their actions lwill be sumarized in the response to the !!RC's letter to the 1lashington Public Power Supply System, dated April 17, 1979. b. Exi-Interview 'r At the conclusion of the inspection a meeting was held with licensee and Burns & Roe representatives denoted in Paragraph 1. The activities covered during the inspection and observations and findings of the inspectors were discussed. The insper tors r'eiterated the need to assure strict procedure. compliance on the reactor recirculation nozzle safe erd replacement job and r other safety-related work activities at the site. Licensee representatives stated innediate actions are being taken to address this and the other items identified during the current inspection. O e

Oy b. (. j g()c Washington Public Power Supply System 3 A JOINT OPERATING AGENCY y$. 25, P. O. D o s 9 8 8 3000 Geo. Wa sumstoss War Recabamo. W a swee.sto= 9 9 33 2 P=O=s (309 8 375 S000 ~, May 18,1979 M;,m'Gk - A G02-79-100 f ThYY es %,5}

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{. Nuclear Regulatory Commission gd, % g, -p / s- - Re9 on V p i 9 .gh' q',,Dr g " Suite 'c02, Walnut Creek Plaza rWalnut Creek, California 94596 Attention: ~ R. H. Engelken, Director

Subject:

UFPSS NUCLEAR PRO.)ECT NO. 2 NRC INSPECTION - FEBRUARY _ 27-28, MARCH 1-2. ~ )AND MARCH 14-16, 1979 DOCKET NUMBER 50-397 ,Meferences: 1)atetter, R. H. Engelken to H. O. Strand, dated q 'f April 17,1979. .,s

1..

2) Letter, D. F. Knuth to all AEC Licensees, dated I

~d December 31,1974, " Criteria for Determining Enforcement Action and Categories of Non-Compliance". i;

NearLMr. Engelken

As requested in reference lettcr, we are implementing additio,nal and immediate actions required to assure that ongoing construction activities are accomplished according to quality requirements. .Since.otjr May 1978 conference, we have initiated actions to strengthen the UPPSS and the contractors QA Programs. However, we still have a need for continuins and increased attention in the following areas: 1. Responsibility of Project Managers, Construction Managers and Supervisors for enforcement of job quality requirements. 2. Improve c6ntractor training and the problem feedback loop to firstline personnel. 3. Improve preplanning to prepare contractors before comencement of Quality Class I work. 4. Streamline contractor procedures to eliminate overly complex and unnecessary requirements. sl's> D ~ a go 0 1l gyg ATTACHMENT 3 %

?.. ( ( Lihjcicar Regulatory Commission _EPage 2; m b < g.. - Some of our. major actions,. planned or undensay, to address these specific areas and our overall-QA Program ?re listed below: . e have initiate <' a detailed assessment and evaluat. ion of our " Quality 1. W \\e Assurance Program Corrective.!!easures," submitted to you by letter of 'E. September 1,1978, in response to our 11ay-June 1978 enforcement conferences, Target for' completion of the evaluation and followup plan of action is u y. July 31,-- 1979. -2s The. Assistant Director-Projects has initiated a program of periodic

• reindoctrination of Project flanagers and their Construction lianagers and Supervisors for enforcement of job quality requirements.

2

WPPSS will instigate the training of craft supervisors and management 3

of-selected major UNP-2 contractors. The training module for craft -.U V supervision is one specially prepared by our architect-engineer for l f oreman level. _ Target date for completion of this modale is August 1979.. [ 4. We are now reviewing with WNP-2 contractors their system for problems feedback to crafts and.firstline inspectors. We will inprove the system g.' where necessary. Expected completion date is June 1979. S. - Before any new Quality Class I work commences, WUP-2 Construction lianagement will ask for a QA audit to generally review the contracto.s' overall readiness. Work will not be allowed to proceed except in i those' areas not affected by the review and audit findings. 6. Because we have been concerned about the adequacy of our contractors' program-for controlling their QA records, we have just audited their programs and will improve them where necessary. He have personnel assigned for ongoing review of records. To gain the necessary assurances, we have assigned and located document review personnel at three of the critical contractors'. document control areas. On Contract 215, our Construction fianagement has been directing an effort to transfer documents from the f; eld to the records vault. 7. In support of our Construction fianagement-Systems Completion Group, we have established a Quality Completion Group with Project QA. The latter group will' support Systems Completion and Startup by timely identification and resolution of inspection backlogs and quality-related deficiencies. - On C' ntract 216, Waldinger has replaced its Project Itanager and QA llanager 8. o and we are demanding their highest corporate attention to solve the QA problems. He are having weekly Project flanagement meetings with them on QA problems. A joint Project-Contractor Task Force of Ennineering/ ' Construction /QA-QC personnel has been started to speed up inspec't sn _ backlogs. By June 1979, we plan to review and streamline Contract 216 procedures to delete overly complex and unnecessary requirements. O

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( } fluclear Pcgulato'ry Cor.nission Page 3-9.- ife are als( 'iaving weekly Project 11anagement meetings with Contract 220 (.lohnson " ' 'ols) on quality problems and are expediting their program inplementatiun. We took stop work actions in April in two areas where existing procedures were inadequate. By June 1979', we plan to review and streamline contractor-procedures-to delete overly complex and unnecessary _ requirements. 10. You are aware that our efforts-significantly improved the 215 Contractor's QA Program over the last one-year period. Because of the size, importance ,and past history of the 215 Centract, we will continue to give thjs contract-our close attention including improvement of hanger inspection backlogs. If you have any questions or desire further information, please advise. Very truly yours,

1. O. Strand Managing Director vh JG Davis - Office of Inspection & Enforcement, Washington, D.Cm t

cc: CR Bryant - BPA I h O e - m i '}}