ML20024D907
| ML20024D907 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/26/1983 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML20024D908 | List: |
| References | |
| NUDOCS 8308080412 | |
| Download: ML20024D907 (7) | |
See also: IR 05000397/1983029
Text
JUL 2 61983
Docket No. 50-397
Washington Public Power Supply System
ATTN: Mr. D. W. Mazur, Managing Director
P.O. Box 968
Richland, Washington 99352
Gentlemen:
SUBJECT: Construction Appraisal Inspection 50-397/83-29
This refers to the Construction Appraisal Inspection by the Office of Inspec-
tion and Enforcement (IE) on May 16-27 and June 6-22, 1983, at the Washington
Nuclear Plant Number 2 (WNP-2) site and your Richland offices. The Construc-
tion Appraisal Team (CAT) was composed of members of IE, Region V, and a number
of consultants. The inspection covered construction activities authorized by
NRC Construction Permit CPPR-93.
This inspection is the third of a series of construction appraisal inspections
being planned by the Office of Inspection and Enforcement. The results of
these inspections will be used to evaluate implementation of management control
of construction activities and the quality of construction at nuclear plants.
The enclosed report identifies the areas examined during the inspection.
Within these areas, the effort consisted of detailed inspection of selected
hardware subsequent to Quality Control inspections, a comprehensive review of
selected portions of your Quality Assurance Program, examination of procedures
and records, observation of work activities and interviews with management and
other personnel.
Appendix A to this letter is an Executive Summary of the results of this
inspection and of conclusions reached by this office. The NRC CAT noted no
pervasive breakdown in meeting construction requirements in the samples of
installed hardware inspected by the team. However, deficiencies in installed
hardware were noted by the NRC CAT which indicate a need for increased manage-
ment attention to the WNP-2 Quality Verification Program. These deficiencies
include the areas of concrete reinforcement steel placement, mechanical equip-
ment installation, the as-built inspection program, weld repairs, and other
detailed deficiencies discussed in the attached report. An indication that
prompt management attention is being given to the identified deficiencies is
contained in the submittal provided to the NRC dated July 15, 1983 entitled,
" Nuclear Project 2 Construction Assessment Team Issues".
8308080412 830726
PDR ADOCK 05000397
IE01
0
.
. _ .
-
.
.
.
.. -
-
--
__
-
JUL 2 61983
Washington Public Power Supply System
-2-
Appendix B to this letter contains a list of potential enforcement actions
based on the NRC CAT inspector observations. These have been referred to tne
Region V office for review and necessary actions.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room unless you notify this office,
by telephone, within 10 days of the date of this letter and submit written
application to withhold information contained herein within 30 days of the
date of this letter. Such applications must be consistent with the
requirements of 10 CFR 2.790(b)(1).
No reply to this letter is required at this time.
NRC Region V will address
the potential enforcement findings at a later date and any required response
will be addressed at that time.
Should you have any questions concarning this inspection, please contact us or
the NRC Region V office.
Sincerely,
. Original signeW.
R. C. Dave"'"?
Richard C. DeYoung, Director
Office of Inspection and Enforcement
Enclosures:
1.
Appendix A - Executive Summary
2.
Appendix B - Potential Enforcement Findings
3.
Inspection Report 50-397/83-29
1
4
9
$
W
f
c
W8""* RCPB:QASIP:IE RCP :QASIP:IE RCPB:QASIP:IE RCPB:QASIP:IE DI -
- IE DI
r
'
RDM d
'g
""*" HWong/vjj
KHerring
RRohrbacher
RHei
JTz
1 or
07/ phman
War /n
07/gf/83
07/;ff83
07/45/83
p g83
07)
83
07/p/83
-
.
.
.-
.
--
APPENDIX A
EXECUTIVE SUMMARY
An announced Construction Appraisal Team (CAT) inspection was performed at the
WNP-2 site during the period May 16-27, 1983 and June 6-22, 1983.
OVERALL CONCLUSIONS
It is the position of the Construction Appraisal Team that the results of this
inspection indicate several construction program weaknesses.
NRC Region V has
been made aware of these weaknesses and is pursuing them with licensee manage-
ment.
The licensee is initiating corrective action and/or continuing efforts
to resolve the identified concerns. An indication that prompt management
attention is being given to the identified deficiencies is provided in the
submittal provided to the NRC by the licensee dated July 15, 1983 entitled,
" Nuclear Project 2 Construction Assessment Team Issues."
The identified construction program weaknesses are as follows:
(1) The "as-built" program for piping and supports, while identifying a number
of hardware deficiencies does not appear completely effective in that the
NRC CAT findings indicate additional deficiencies, some of which are
considered significant.
In addition, the subsequent audit conducted by
the licensee of a larger sample found essentially the same types of
deficiencies as those identified by the NRC CAT inspectors.
(2) The reinforcing steel placement deficiencies identified during the
inspection indicate questionable conditions which require additional
destructive examination or analysis to determine the effects on the
structures.
(3) Several wel-is were identified that appeared to the NRC CAT inspectors to
have linear type root indications which were not in accordance with code
requirements.
In addition, weld repairs were not controlled to ensure
that the proper areas were repaired and that the repairs were adequately
performed.
(4) Mechanical equipment deficiencies identified during the inspection indi-
cate questionable bolting installation and control of parts.
i-
In summary, the identified weaknesses require increased attention by management
at all levels to assure completed installations meet design requirements.
AREAS INSPECTED AND RESULTS
,
Electrical and Instrumentation Construction: Activities in the electrical and
'
instrumentation construction areas appear to be adequate. Although deviations
from requirements were observed in QC accepted hardware, these were isolated
and not considered repetitive in nature.
The existing program for inspection of electrical raceway does not appear
completely adequate to verify that redundant cable trays are installed in
accordance with the applicable separation criteria.
j
,
A-1
d_
The review of records associated with the corrective action system and several
deficiencies observed in battery and instrument rack hardware, indicate that
the applicants startup and test work activities in that area were ineffectively
controlled by the existing quality control program.
Mechanical Construction:
Deficiencies identified by the NRC CAT and subsequent
licensee / contractor inspections indicate that some pipe and pipe support /
restraint deficiencies have not been identified by previous as-built programs.
Quality Class II, Seismic Class I supports / restraints significantly deviate
from design drawings and are not included in the as-built program.
Expansion
anchor bolts for pipe supports appear to be adequately installed.
Significant
deficiencies were identified in the area of installation of fasteners and other
mechanical equipment. The deficiencies involve:
foundation bolts for
non-rotating equipment; bolting torques for rotating and non-rotating equip-
ment; control of materials and parts for roechanical equipment; and the absence
of visible marking and traceability records on the RPV holddown studs. The
HVAC systems appeared to have been constructed in accordance with requirements
except for minor discrepancies in installed hardware.
Welding / Nondestructive Examination: Several hardware problems were identified
relating to welding /NDE activities. Welder qualifications and vendor radio-
graphic film appear to conform to requirements. Weaknesses were identified in
the onsite welding inspection and NDE program. Areas requiring evaluation
and/or corrective action are: (1) weld repairs, (2) identification of linear
type root indications in piping welds, (3) weld surface preparation for perfor-
mance of liquid penetrant tests and (4) proper weld reinforcement on
weld-o-lets.
Civil and Structural Construction:
There is not reasonable assurance that the
reinforced concrete members and structures were constructed in conformance with
design requirements. This conclusion is supported by the findings that rebar
placement deficiencies were identified in 10 of 12 examined locations, inspec-
tion records and NCR dispositions were found in a number of cases to be erro-
neous, and the accuracy of the design drawings with regard to associated design
calculations is questionable. Structural steel installations appear to be
satisfactorily assembled except for some deficiencies in structural steel
welding. These deficiencies include undersized fillet welds on containment
penetration stiffeners. The structural steel reverification program may not be
adequately justified when considering that allowed weld deviations and critical
connections were not considered in the analysis.
Material Traceability, Storage, and Maintenance:
Procurement, onsite storage
and maintenance were found to be generally acceptable. Material traceability
of steel, weld filler material, mechanical equipment and electrical components
was consistent with requirements, however, problems were identified in the area
of fastener traceability. Specifically, improper or uncontrolled material
substitutions was noted with respect to fastener quality on pipe flanges, valve
bonnets, mechanical connections and pump couplings.
QC Inspector Effectiveness:
Interviews were held with 43 inspectors randomly
selected from contractors on the construction site. There were no instances of
intimidation or threats reported.
A-2
.
Quality Assurance: Selected portions of the QA program were reviewed. A
program of formal audit and surveillance was in place to monitor construction
activities and measuring and test equipment was controlled. Weaknesses were
identified in Quality Control for work performed during the Test and Startup
Phase.
In this area, these weaknesses included:
inspectors were not free from
schedular requirements in some cases; some inspector qualifications did not
appear to meet Supply System commitments; the program did not ensure that
deficiencies were corrected; and in some cases the corrective actions were not
documented and the records properly maintained.
i
,
A-3
.__
..
.
_
. _ _ _ - .
.
_ _ _ _ . . _ _ . . _ . _ . _
. ._
. _ . . . , _ _
APPENDIX B
POTENTIAL ENFORCEMENT FINDINGS
As a result of the CAT inspection of May 16-27 and June 6-22, 1983, the
items have been referred to NRC Region V as potential enforcement
following(Section references are to the detailed portion of the Inspection
findings
Report).
Mechanical Construction
1.
Contrary to 10 CFR 50, Appendix B, Criteria II, III and XVI; and FSAR
Sections 17.1.1.2, 17.1.1.3 and 17.1.1.16; Quality Class II/ Seismic
Category I piping supports have in some cases not been constructed and
inspected to sufficient quality standards to provide assurance of their
structural integrity commensurate with their importance to safety.
(Sections III.B.2 and 3)
2.
Contrary to 10 CFR 50, Appendix B, Criteria X and XVI, and FSAR Sections
17.1.1.10 and 17.1.1.16, the applicant's "as-built" verification program for
Quality Class I piping and supports has not successfully provided for
the identification of discrepancies between design, drawings and in-situ
configurations. Although relatively minor, the number of discrepancies
found is indicative that the program has not fully achieved its objective.
(SectionIII.B.3)
3.
Contrary to 10 CFR 50, Appendix B, Criteria III, VIII, X, and XV; and FSAR
Sections 3.9, 17.1.1.2, 17.1.1.3, 17.1.1.8, 17.1.1.10 and 17.1.1.15; the
design and installation of mechanical equipment has not been adequately
controlled to provide assurance of their structural adequacy and function
under all postulated operating and design basis events. The NRC CAT
examinations indicated lack of bolt torquing control, failures of bolting
to sustain specified torque values, installation procedures inadequate
with regard to certain bolting, and inadequate control of fastener instal-
lation.
(Sections III.B.6 and 7 and VI.B.1)
Welding and Nondestructive Examination
1.
Contrary to 10 CFR 50, Appendix B, Criteria II and X; and FSAR Section
17.1.1.2 and 17.1.1.10; several examples were noted where licensee exami-
nations and inspections did not result in the identification of rejectable
defects in radiographic film, insufficient weld reinforcement for
weld-o-lets, and rejectable liquid penetrant (PT) indications.
(Sections
IV.B.1, 4, and 5)
2.
Contrary to 10 CFR 50, Appendix B, Criteria V, X, and XVI; and FSAR
Section 17.1.1.2, 17.1.1.5, 17.1.1.10, and 17.1.1.16; examples were noted
where corrective actions and inspection activities were not adequate to
provide assurance that piping weld repairs were properly made. (Section
IV.B.4)
B-1
Civil and Structural Construction
1.
Contrary to 10 CFR 50, Appendix B, Criteria III, X and XVI; and FSAR
Section 3.8, 17.1.1.2, 17.1.1.3, 17.1.1.10 and 17.1.1.16, several cases
were noted where design controls and inspection activities were not
sufficient to provide assurance that reinforcement steel placement is in
accordance with the ACI 318-71 Code and design requirements. The NRC CAT
inspection of a sample of concrete structures indicated inadequate rebar
placement not noted in inspection records, inadequate NCR and RFI disposi-
tions, and design drawings not conforming with design calculations.
(Section V.B.2)
2..
Contrary to 10 CFR 50, Appendix B, Criterion I; and FSAR Section 17.1.1.1;
the civil / structural organization provided several erroneous NCR disposi-
tions which had nonetheless received all appropriate checker / supervisory
approvals.
(Sections V.B.2 and 4, and VI.B.1)
Quality Assurance
1.
Contrary to 10 CFR 50, Appendix B, Criterion XVI and FSAR Chapter 17.1.1.2
controls in the Test and Startup Organization were inadequate to ensure
that deficiencies, identified in sebcontractor inspection reports, were
in fact corrected.
(Sections II.B.11 and VIII.B.2.d)
2.
Contrary to 10 CFR 50, Appendix B, Criterion I and FSAR Chapter 17.1.1.2
centrols were not established in the Test and Startup Organization to
insure that QC inspections were performed by individuals who were indepen-
dent from schedular responsibility.
(SectionVIII.B.2.d)
t
B-2
_
. - . - - .
--
-
.
. - - _
- - - . _ _
. - _ .
-.