ML20038B833

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IE Insp Repts 50-460/81-07 & 50-513/81-07 on 810815-0907 & 14-18.Noncompliance Noted:Failure to Perform safety-related Work to Approved Procedures Re HVAC
ML20038B833
Person / Time
Site: Washington Public Power Supply System
Issue date: 11/12/1981
From: Dodds R, Hernandez G, Narbut P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20038B816 List:
References
50-460-81-07, 50-460-81-7, 50-513-81-07, 50-513-81-7, NUDOCS 8112090139
Download: ML20038B833 (14)


See also: IR 05000460/1981007

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U. S. NUCLEAR REGULATORY DMMISSION

0FFICE OF INSPECTION AND ENFORCEMENT

REGION V

50-450/81-07

Report No. 50-513/81-07

Docket No. 50-460, 50-513

License No. CPPR-134, 174

Safeguards Group

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Licensee: Washington Public Power Supply System

P. O. Box 968

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Richland, Washinaton 99352

Facility Name: Washington Nuclear Projects Nos. 1 & 4 (WNP-1/4)

Inspection at: WNP-1/4 Site, Benton County, Washington

Inspection conducted: ' August 31 - September 4,'a'nd September 14-18, 1981

Inspectors:

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P. P. Narbut, Reactor Inspector

Date Signed

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G

ernandez,ReactoOInspector

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Approved by:

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R.' T. Dodds, Chief, Reactor Project

'Datv Signed

-Section 2, Reactor Construction Projects

Branch

Summary:

Inspection during the period of August 31 - September 4, and September 14-18, 1981

Areas Inspected:

Routine, unannounced inspection by regional based inspectors of construction

activities including licensee action on previous inspection-findings, welding

and equipment storage for the safety related tank manufacturer, containment

penetration installations, construction shutdown maintenance activities for

the WNP-4 unit, and examination of allegations against the heating, ventilation

and air-conditioning (HVAC) contractor and the civil structural contractor.

The inspection involved 91 inspector hours onsite by two NRC inspectors.

Results: Of the four areas examined, no items of noncompliance or deviations

were identified in three areas.

One apparent item of noncompliance was

identified in the investigation of allegations directed at the HVAC

contractor - failure to perform safety related work to approved procedures.

8112090139 811120

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DETAILS

1.

Individuals Contacted

a.

Washington Public Power Supply System

  • R. B. Glasscock, Director Quality Assurance
  • D. W. Mazur, Program Director
  • F. C. Hood, Manager, QA and. Safety

+C. B. Organ, Assistant Project Director Engineer

  • +J. P. Thomas, Assistant Project Director, Construction
  • R. F. Mazurkiewicz, Project Management Specialist
  • +C. R. Edwards, Project QA Manager

+M. E. Rodin, Senior QA Engineer

  • M. J. Farrell, QA Engineer
  • J. M. Steidi, Senior QA Engineer
  • W. Root, Assistant Program Director, Construction
  • G. K. Dyckman, Design Engineering Manager

R. E. Brown, QA Engineer

b.

Bechtel Power Corporation (Bechtel)

  • +E. W. Edwards, Project Manager
  • +J. Gatewood, Project QA Engineer
  • +J. Ruud, QA Engineer

+H. P. Danies, Project Superintendent

+D.. Henry, QC Engineer

  • +T. F. Fallon, Project Construction QC Engineer
  • G. A. Hierzer, Field Construction Ma' nager

J. Jabaly, Lead Document Engineer

D. R. Johnson, Manager of Quality

G. Minor, QC Engineer

United Engineers and Constructors (UE&C)

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+G. M. Ahearn, Acting Project Manager

+R. H. Bryans, Manager, Construction Support

+W. R. Marchland, FSQA Division II

  • +G. L. Faust, QA Field Superintendent

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+K. J. Iverson, Assistant Manager Construction Support

  • E. C. Haren, Project QA Manager

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D.- Gardiner, Lead Structural Engineer

N. D. Amaria, Supervisory Structural Engineer

A. Zindel, Design Engineer

B. Anderson, Design Engineer

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d.

J. A. Jones, Construction Company (JAJ)

+P. R. Cortez, Project Manager

+K. Dempsey, Construction Manager

+W. Roe, Project QA Manager

e.

University Nuclear Systems Inc. (UNSI)

  • L. Graydon, Construction Manager
  • B. Sachs, Project QA Manager

J. McCafferty, Welding QC Engineer

D. Jones, QC Supervisor

C. Holt, Assistant QA Manager

M. .Shultz, . Project Manager

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G. F. Atkinson, Wright, Schuchart/ Harbor (AWSH)

M. Latch, QA Manager

D.~ Dickey, Lead Welding QC Engineer

g.

Welk Brothers Inc.

+M. Thomas, Project Manager

+M. Saruwatari, QA Manager

R. Kainu, Welder

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M&M Inc (M&M)

M. Fourier, Project Manager

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Bonneville Power Administration (B' PA)

  • C. R. Bryant, Project Engineer

+ Attended Exit. Interview 9/4/81

  • Attended Exit Interview 9/18/81-

2.

Licensee Action on 50.55(e) Construction Deficiency Reports

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a.

(Closed) 50.55(e) of 1-30-80 Re:

Nonconforming Retraining Clips

on WKM Gate Valves (WPPSS ltr G01-80-68 of 2-11-80)

The inspector verified triat the valve records packages had the

retaining clip repair records included in the permanent file.

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b.

(Closed) 50.55(e) of 12-18-80 Re: Bostrom Bergen Metal Products

Welded Assemblies (WPPSS ltr GO-1-81-03 of 1-7-81)

The licensee submitted several interim reports and a final

report, letter G01-81-260 of 8/19/81. The inspector verified

the actions specified in that letter had been taken through

interviews with the involved personnel. The inspector specifically

discussed the mockup samples of weld defects which were tested

to destruction. Although there was some question as to the

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exactitude of the mockup samples, the testing results were so

conservative that the inspector had no further concern. The

inspector examined the quality of welding on nine Bostrom

Bergen embedments to assess the degree of nonconformity with

code requirements. Based on the actions taken as reported in

the licensee's response, this item is considered closed.

c.

(Closed) 50.55(e) of January 8,1980 Re:

Diesel Generator Combustion

Air Intake Design Deficiency (WDPSS ltr G01-1-81 of 1/6/81)

The licensee submitted a final report (letter G0-1-81-202) on

July 9, 1981. The inspcetor examined .the actions described in that

letter and its references. The actions appear to have been implemented

as stated. The inspector observed that one of the actions,.

the addition of louvres which are designed to minimize water

passage, is on hold for a volcanic ash study. However, this

50.55(e) item is considered closed since all the committed

changes are included in the licensee's contract change orders

and the licensees design change tracking system app' ears adequate.

For record purposes the design change is described in the

licensee document PCP-14S 00093 of June 26, 1981.

d.

(Closed) 50.55(e) (Potential) of January 7,1981 Re: Decay Heat

Removal Heat Exchangers

The licensee submitted a final report, letter.G01-81-194 of

July 2,1981, which stated that the condition had been

determined to be not reportable. Based on the; submission

of the final report and the inspector's prior examination,

discussed in report 50-460/81-06, this item is considered closed.

3.

Safety Related Components - Water Tank Manufacture

a.

Material Storage

During a general walk through examination of the site, the inspector

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observed improper storage of piping and nozzles for the borated

and demineralized water storage tanks. The inspector observed

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four pieces stored in a skip box, eight pieces off their dunnage

and laying in the sand which is contrary to the Welk Brothers

storage procedure. One of the pieces (Nozzle D8, Tag N93, Ht

855071) was abnormally rusty for stainless steel and had what

appeared to be rusty scale inside the nozzle.

The. inadequate storage and abnormal rust conditions

were subsequently documented on nonconformance reports

1-CNCR-243-12 and 13.

At the exit interview the licensee management committed to

determine the cause of the unusual rust accumulation of the

stainless steel nozzle as part of the corrective action to

the CNCR. The cause of the rust will be examined further

in a future inspection.

Followup item (50-460/81-07/01)

The inspector interviewed the Bechtel QC surveillance

inspector responsible for Welk Bros. and examined the

surveillance records for the month of August 1981. The

records indicated that the Bechtel surveillances were reasonably

thorough and had identified similar storage problems which

had been corrected. The condition observed by the inspector

was apparently a recent occurance caused by moving the

equipment.

b.

Tank manufacture

The inspector examined certain aspects of.the manufacture

of the boric acid water storage tank for compliance to the

Welk Brothers procedures and ' interviewed a welder and a weld

rod issue station attendent. The aspects of manufacture

observed were welding of a tank vertical weld, weld rod

control, use of work travelers, and verification that a welder -

qualification record, weld p~rocedure qualification record and

weld procedure specification were on file for the welder

and process observed in use.

No items of noncompliance or deviations were observed.

The inspector noted, however, that the QC inspectors were not

indicating preheat reauirements had been met on the weld traveler

form.

Interviews established that preheat requirements were, in

fact, being met but the OC. inspectors initialed the preheat

reauirement box on the form only when a heating device was used

versus when-the preheat requirement was met.

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The inspector also determined that the Welk Bros. QC inspectors

are not formally certified as inspectors as indicated by Regulatory

Guide 1.58

These two items will be inspected further in a future inspection

(Followup-Item 50-460/81-07/02)

4.

Allegations against University Nuclear Systems Inc. (UNSI)

The NRC received two specific allegations against UNSI. Those

allegations and other suggestions of problems gathered through

interviews with UNSI personnel are detailed below.

a.

Allegation: Crafts are working to "information only" drawings

rather than " released for construction" drawings.

Finding: The allegation was substantiated but is not a safety

concern.

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Discussion: QC. personnel interviewed indicated they had not

inspected to'the information only drawings. UNSI quality

assurance management personnel stated that they were aware of the

situation but did not consider a problem existed since final OC

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acceptance inspections were not being performed.

Bechtel letter

BECUE-81-5126 o.f August 4,1981, recognized and documerited the

situation.

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The problem developed as follows:

(1) UE&C prepared contract drawings provide the necessary

engineering information for HVAC installation.

(2) UNSI prepares shop drawings from the contract drawings but

does not make any engineering changes.

(3) Currently, UE&C is required to approve the UNSI drawings

prior to release for construction. The UE&C review time

is delaying construction of the HVAC systems.

(4) To eliminate the delay, UNSI, with Bechtel concurrence, is

allowing construction to proceed with information only (not

reviewed by UE&C) drawings while working on a program change

which would authorize UNSI to release drawings for construction

with UE&C approval to be obtained on a noncontrolling basis.

At the exit interview the inspector noted that the proposed

method of UNSI release of shop drawings did not apparently

include a systematic method of assuring that the UE&C did

approve the drawings prior to final acceptance of the completed

and inspected work.

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The licensee action to ensure that.the' designer, UE&C,

approves drawings:used to perform work prior to final

acceptance of that work is considered a followup item.

(50-460/81-07/03)

b.

Allegation: Welder performance . test bend samples are selectively

removed so that the best part of the weld is bend tested.

Finding: The allegation was not substantiated. The allegation

was directed against M&M Inc. which performs welder qualification

for UNSI- at the WNP-1/4 site.

Discussion: The sampling technique was found to be in accordance

with AWS D.l.1 1977 Edition.

Interviews with the weld examiner

indicated that the method of sample selection was consistent

from welder to welder that is, the bottom inch of. the six inch

test plate is removed and discarded then two consecutive 1/2"

samples are removed for bend testing. The. inspector examined

welder test records and determined of the 24 welders tested for

UNSI by M&M Inc. eight had passed and sixteen had been failed.

This does not indicate selectivity on the part of the weld examiner.

c.

Other Items

Other items which came up persuant to the followup of the original

two allegations were investigated. .The items 'and results are

as follows:

(1)

Item:

Tack welds are not being inspected because

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construction is not notifying inspection.

Finding:

Partially substantiated.

Discussion: The problem divides. into two parts; tack welds

for temporary attachments and tack welds for fitup of

permanent items.

This problem was identified by request for information RFI-4-277

of June 16, 1981 for temporary attachment welds UNSI QA

management issued a new procedure revision for Bechtel review

and approval _on July 21, 1981. The procedure change was

approved by Bechtel for.use on September 15, 1981 (during

theinspection).

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The procedure change as issued appears to violate the AWS

D.1.1 inspection requirements in Section 6 for the quality

requirements of pragraph 3.3.7.

It appears that the original

problem identified (construction bypassing inspection)

was not properly resolved.

The second part of the tack weld problem (. tack welds for

fitup of permanent items) was not pursued during this inspection.

This item is considered unresolved.

(Unresolved Item

(50-460/81-07/04)

(2) . Item:

QC inspectors are intimidated.

Finding:

Partially substantiated but not a safety

concern because there were no indications of inspections

having been performed improperly.

Discussion: There were several items or incidents involved

in this category. There was one specific allegation that,

in a meeting of inspectors, the QA manager refused.to give

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a QC inspector the NRC telephone number. By interviewing

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the involved QC inspector and the QA manager, it was determined

that the particular individual was not intimidated but that

other QC personnel considered the QA manager response

intimidating.

Another item is that several QC inspectors felt ~that writing

a conconformance reports (CNCR's) could get them in trouble and

that it was d;3tinctly undesirable to write CNCR's. Discussions

with other QC. inspectors and the QA' manager indicated that the

intent of statements made was to avoid writing unnecessary

CNCR's and to ensure adequate research of requirements was

done prior to writing the CNCR. The inspectors interviewed

were mixed in their response; some understood the message

as the QA manager intended it, others perceived it as intimi-

dation.

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At the exit interview licensee management ccmmitted to

evaluate the actions necessary to correct this potential

intimidation. This item will be inspected further in a

future inspection.

(Followup. item 50-460/81-07/05)

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Item: PC Requests for Information (RFI's) are not being

answert ' in a timely manner.

Finding: This item was not investigated during this -

inspection and will be examined further in a future

inspection. Of the examples discussed, one was a QC

RFI-349 of August 25, 1981 in which angle support members

supported from structural steel ware not located per

drawing requirements. The RFI-identified the fact that

other already inspected and accepted supports may have the

same condition. Another example was QC-RFI-277 of

June 16, 1981 dealing with the problem ~of construction not

calling for inspection of tack welds.

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This item will be inspected further in a, future inspection

(Followup Item 50-460/81-07/06).

. ork is being done to memorandums!instead of

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Item:

W

procedures.

Finding: Substantiated.

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Discussion: The' inspector confirmed that work was done

to UNSI memorandums rather than approved procedures.

Memorandums do not have the benefit of formal change control,

or licensee review and approval.

Examples of the use of memorandum in lieu of procedures

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were discussed with various personnel.

One example dealt with the quality related activity of

generating as-built drawings. A contract change order

was issued to UNSI to perform an as built check of the

installed HVAC ducts and hangers-against drawing requirements.

The instructions to Quality Control personnel on how to

perform these inspections were issued as inter office

memorandums QA 412 of June 29,1981, QA 412 Revision 1 of

7/8/81, QA 412 Revision 2 of September 7,1981 and

speedletter BLS-247 of September 18,.1981.

Speedletter

BLS-247 changed tolerances to +1/4" whereas as the

miscellaneous construction tolerance given on UE&C Drawing

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9779-L-604900 Sheet MI 2 states that unless otherwise noted,

all dimensions are to have a tolerance of +1/8".

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A second example dealt with speed letter 9303 dated

June 2,1981 which implemented a proposed change to QCP/CP-27.0

prior to changing the procedure. The change dealt with

documentation.

A third example was speedletter BLS-250 of September 3,1981

which authorized work on a defective tap-in piece rather

than having the work instructions provided on a CNCR

dispositioned by engineerin.g personnel per the requirements

of QCP CP 10.0, Nonconforming Materials, Parts and Components.

Procedure QCP/CP10.0 paragraph 5.22 requires all nonconformances

be dispositioned on the original nonconformance report and

that the nonconformance receive engineering concurrence.

The failure to accomplish activities affecting quality in

accordance with documented instruction is an apparent item

of noncompliance.

(Enforcement Item 50-460/81-07/07)

(5)

Item:

Procurement controls were bypassed in procuring a

quality related item.

Finding: Substantiated for the initial actions.

Discussion: The inspector noted a great deal of apparent QC

inspector unrest due to what was perceived as a management attempt

to circumvent quality control systems for the procurement of a

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piece of schedule controlling quality related duct work. The

piece in question was a " tap-in" piece, Pc13-904053.

The item was purchased from a local sheet metal fabricator who

did not have a contract for quality class 1 material. The purchase

was conducted informally by the UNSI Project Manager and the item

initially bypassed normal receipt inspection controls. ~ It was

apparent to the inspector through discussions with involved.

personnel that the entire issue was an emotional one in the UNSI

organization. The final actions on this item by the UNSI

organization were proper. That is, the hardware item was

written up on a nonconformance report and a corrective action

request was written by UNSI QA to UNSI managenent for the problem

of bypassing procurement controls.

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At the exit interview the inspector discussed this procurement

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item with licensee management. One item of concern to the

inspector was the fact that although the new Bechtel

organization was in place and working level Bechtel personnel

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were aware of these procurement actions neither the site Bechtel

QA management or licensee QA personnel were aware of this rather

high level contractor departure from good quality control practices.

The inspector ellicted and received a committment from licensee

management to consider and to describe, in correspondance to

the NRC, the adequacy of the threshold for Bechtel forces to

notify WPPSS management of significant quality problems, and

secondly the adequacy of the current WPPSS/Bechtel system to

detect and resolve quality related unrest at working level. An

additional example discussed at the exit interview related to

unrest of J. A. Jones inspectors previously described in

Inspection Report 81-06, paragraph 5.e..

The licensee response is considered a followup item (50-460/81-07/08).

5.

Containment Penetrations

a.

Review of Quality Assurance Implementing Procedures

The inspector examined the following specifications and drawings,

which govern the purchase, handling and installation of

electrical, mechanical and piping containment penetrations for

conformance to PSAR, ASME B&PV Code and ANSI standard requirements:

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(1) Specification Number 9779-148- Containment Piping

Penetrations (contractor: Nissho-IWAI).

(2) Specification Number 9.779-213- Containment Liner

(contractor: Pittburgh-Des Monies Steel Company)

(3) Specifi~ cation Number 55-Containment Electrical Penetrations

(contractor: Westinghouse Electric Corporation)

(4) United Engineers and Constructors Drawing Nos.-9779-5-805313,

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9779-S-805311, 9779-S-805312, and 9779-S-805310.

(5) Westinghouse Electric Corporation Drawing No. E-40196.

(6) The applicable contractorLproceaares for installation of the

containment penetrations were also reviewed.

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The inspector noted that the containment mechanical and piping

penetrations are being welded and weld procedures qualified

to Section III, Division 1 of the ASME Code. Discussion with

the cognizant engineer indicated that all, penetration field welds

would be tested as required by the Code during the Structural

Intergity Test (SIT). However, the inspector noted that the SIT,

as specified in Section 6000 of Division 2 of the Code, requires

that the containment be pressurized to 1.15 of design pressure.

The welds therefore, would be tested below the test 3ressure

specified in Division 1.

Division 1 requires that t1e welds be

hydrostatically tested to 1.50 or pneumatically tested to 1.25 of

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design pressure.

The licensee stated that they would investigate and resolve this

issued. This item will be examined further during a future

inspection. This is a followup item (_50-460/81-07/09).

b.

Observation of Work and Work Activities

The inspector examined work, activities associated with the

following containment penetrations:

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(1) Penetration No. 88, S/N 4066

(2) Penetration No. 52, S/N 4062

(3) Penetration No. 60, S/N 4116

(4) Penetration No. 50, S/N 4045

(5) Penetration No. 6, S/N 4091

(6) Penetration No. 4, S/N 4090

Activities examined included storage and maintenance of

genetration assemblies, cleanliness of internal surfaces, rigging

end handling of penetration at work locations, completeness of

work release packages, control of weld filler material, and NDE

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examination of weld repairs.

During the examination several

installed penetrations on the westside of the containment were

found without protective covers'(penetration Nos. 35 and 16), a

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paint can was found inside penetration No. 6, and one multiple

head penetration No. 50 hag all o'f the ends uncovered and one

of the sleeves was bent 10 . All of these discrepancies were

immediately documented on a Surveillance Report Number

1-211-002 by the licensee.

No items of noncompliance or deviations were identified.

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c.

Review of Quality Records

The inspector reviewed the quality records for the above penetrations

for compliance to the licensee's specifications, procedures, and

industry standards. The records reviewed included process

control sheets, quick fix change proposals, request for information,

contract waiver requests, pipe weld /NDE records, weld filler

material records, NCR's and applicable drawings.

No items of noncompliance or deviations were identified.

6.

Allegations Regarding AWASH-(Civil Contractor)

Allegation: AWASH Cadweld personnel are performing only sister splice

testing and are not taking production splices in their sampling program.

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Finding: Not substantiated.

Discussion: The inspector interviewed records. personnel and examined

a sampling of Cadweld test records. Essentially all test samples were

production splices not sister splices.

7.

Unit 4, Long Term Shut Down

The inspector initiated an examination of the long term shutdown of

the WNP-4 site. The examination was a physical inspection only and not

an examination.of personnel and maintenance systems.

In general, very

-little. equipment has been installed. There were some pumps, heat

eyr. hangers, fan units, and the diesel generators. The pressurizer is

the only major component installed.in the containment.

The general physical . condition appeared satisfactory, fire loading

was very low.

In general, all electrical equipment and motors had

heaters energized.

A few exceptions were noted but these appeared

to be isolated cases and action was initiated by the licensee to

revolve those deenergized heaters.

The inspector noted one structural column base wgich was in standing

water. The column at elevation 399, azimuth 150 , was in a concrete

blockout which formed the water " trap". Had construction been finished,

the blockout would have been concreted in and no water trap would exist.

Since the length of layup time is unknown, but may be extensive, corrosion

wastage of hold down bolts is a concern. Therefore, the item will be

inspected further on a future inspection.

(Followup item: 50-513/81-07/10).

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8.

Unresolved Items

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Unresolved items are matters about which more information is required

in order to ascertain whethes they are acceptable items, items of

noncompliance, or deviations. An unresolved item disclosed during

this inspection is discussed in Paragraph 4.c.(.1) of this report.

9.

Exit Interview

The inspector met with the licensee representatives denoted in

paragraph 1 on September 4 and 18,1981. -The scope of the inspections

and the. inspectors findings as noted in this report were discussed.

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