ML20039B267
| ML20039B267 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 11/30/1981 |
| From: | Dodds R, Narbut P, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20039B260 | List: |
| References | |
| 50-460-81-09, 50-460-81-9, 50-513-81-09, 50-513-81-9, NUDOCS 8112220473 | |
| Download: ML20039B267 (15) | |
See also: IR 05000460/1981009
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U.S. NUCLEAR REGULATORY COPMISSION
OFFICE OF INSPECTION AND Ehf0RCEMENT
50-460/81-09
Report No.
50-513/81-09
Docket No. 50-460, 50-513
License No.
CPPR-134, -174
Sa,feguards Group
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Licensee:
Washington Public Power Supply System
P. O. Box 968
Richland, Washington 99352
Facility Name:
Washington 1;uclear Projects Nos.1 & 4 (WNP-1/4)
Inspection at:
WNP-1/4 Site Benton County, Washington
. Inspection conducted:
October 1, 9 & 19-23, 1981
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Inspectors:
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P. P. Narbut, Reactor Inspector
Date Signed
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A. D. Toth, Resident ' Inspector
Date Signed
Approved by:
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R. T. Dddds, Chief, Reactor Project Section 2,
Date Srig~ned
Reactor Construction Projects Branch
A.
Inspection during the period of October 19-23, 1981
Areas Inspected:
Routine, unannounced inspection by regional-based
inspector of construction activities including licensee action on
previous inspection findings, and examination of allegations against
the heating ventilation and air-conditioning (HVAC) contractor
(UNSI). The inspection involved 40 inspector hours onsite by one
NRC inspector.
Results:
No items of noncompliance or deviations were identified.
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B.
Inspections during the period of October I and 9,1981
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Area Inspected:
Routine, unannounced inspection by the WNP-2
resident inspector of backshift construction activities in the
piping area at WNP-1/4. The inspection involved nine inspector
hours onsite by one NRC inspector.
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Resul ts: One item of noncompliance was identifihd concerning lack
of appropriate acceptance criteria for-skewed fillet welds.
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DETAILS
1.
Individuals Contacted
a.
Washington Public Power Supply System
+C. R. Edwards, Project QA Manager
+T. C. Hood, Manager, Construction
- +M. E. Rodin, Senior QA Engineer
b.
Bechtel Power Corporation (Bechtel)
+E. W. Edwards, Project Manager
+J. B. Gatewood, Project QA Engineer
+J. Ruud, QA Engineer
+C.
K. Kasch, APC QCE
+G. A. Hierzer, Field Construction Manager
+T. Fallon, PC QCE
c.
United Engineers and Constructors (UE&C)
E. C. Haren, Project QA Manager
G. L. Faust, FSQA
d.
University Nuclear Systems Inc. (UNSI)
+S. Cohen, Project Manager
+B. Sachs, Project QA/QC Manager
+R. Canipe, Corporate QA Manager
+L. Graydon, Construction Manager
+ Attended exit interview 10/23/81.
The exit interview was also
attended by G. Hansen, State of Washington, EFSEC.
- Attended exit interview of 11/2/81.
2.
Licensee Action on Previously Identified Items
a.
(Closed)(460/80-16-02) Enforcement Level IV Item:
Failure to
post supplier drawings with WPPSS quality class
The inspector examined the actions descri;ed in the licensee
letter G01-81-031 of February 3, 1981. T he licensee's action
was to delete the contract specification requirements for
posting WPPSS quality class on vendor staplied item drawings.
It is not typical for vendor prepared product drawings to
include unique purchaser information and the licensee identifies
quality class requirements by means other than posting on
vendor drawings.
This item is considered closed based on the
licensee's actions.
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b.
(Closed) (460/80-16-04) Enforcement Item. Level IV: Pipe-
support configuration does not conform to drawing
The inspector examined the licensee's' actions described in
letters G01-81-031 of February 3,1981-end G01-81-58 of March 5,1981.
The licensee had sampled 66 supports, found three problems and
subsequently analyzed those problems to be acceptable as-is.
Other actions were to increase inspection by the vendor (Huico)
and by vendor surveillance personnel (UE&C).
Huico personnel
received additional training. Additionally, an NRC inspector
had followed up on this item in report'460/81-04 and examined
the UE&C engineering rationale for the acceptance of the not-
per-drawing configuration.
Based on the licensee's response and the inspector's review of
the documentation of the actions taken, this item is considered
closed.
c.
(Closed)(460/80-11-02) Enforcement item; infraction:
Unauthorized removal of arc strikes
The inspector examined the corrective action described in the
licensee responses G01-80-347 of 11/6/80 and G01-81-20 of
1/27/81. The documentation of the repair and corrective craft
training were reviewed. This item is considered closed.
d.
(0 pen)(460/80-01-01) Enforcement Item; infraction
Temporary welds to structural steel are not controlled
The initial problem identified dealt with the welding of
tempa 'ary supports to structural steel without a procedure or
inspection requirements. The licensee response (G01-80-140 of
5/7/80) identified actions that would be taken. Those actions
were examined and discussed in Inspection Report 460/81-01.
In that report, an additional problem was identified - that
one disposition was evaluated as acceptable as-is but identified
welding to thicker than 1 " structural steel.
The licensee
stated an evaluation of those CNCR's, dealing with welding
without. preheat on thick columns, would be perfomed.
Since that previous inspection, the licensee reviewed CNCR's
which dealt with welding without preheat on thick columns.
The licensee limited his review to a sampling of JA Jor.ns
contract 257 CNCR's (did not include JA Jones Contract 211),
and stated they had identified numerous CNCR's with lack of
preheat on thick column welding.
The inspector examined the CNCR log for the period 7/24/81 to
10/21/81 and 9/12/80 to 3/12/81 and determined that welding
without preheat was not an ongoing problem.
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The inspector examined a sampling of the numerous CNCR's
identified by the licensee and noted that they dealt with
permanent welds, not temporary welds, and that they were
dispositioned acceptable as-is without explanation.
The licensee did not have an evaluation of these welds as
committed in report 460/81-01.
Additionally, it appears the initial actions on this item were
not of sufficiently broad scope since'the problem of welding
without preheat or inspection was identified in another contractor's
area (see caragraph 3.J.(5) of this report). The pursuit of
this problem in other contractor areas apparently needs to be
addressed but will be tracked as part of the item in paragraph
3.J.(5).
This item remains open pending review of a licensee evaluation
of JA Jones CNCR's as previously committed.
3.
Allegations against University Nuclear Systems Inc. (UN51)
The inspector examined additional allegations made against UNSI,
the heating ventilation and air conditioning (HVAC) contractor.
The allegations, suggestions of other problems gathered in the
course of the investigation, and followup of previous allegations
(see report 50-460/81-07) are detailed below:
a.
Allegation: Some UNSI QC inspectors were not conscientious.
No specifics were provided.
Finding:
The allegation was not pursued by the inspector
based on the previous inspections interviews with inspection
personnel.
The issues uncovered there dealt with weak UNSI
quality control practices; not personal characteristics.
b.
Allegation:
General QC/QA attitudes were poor.
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Finding:
Not pursued for the reasons given in 3.a. above.
c.
Allegation:
Improper instructions given to staff for dealing
with NRC.
Finding:
Not substantiated.
Discussion:
Interviews with the specific individual identified
did not identify any improper instructions given to him.
d.
Allegation:
The Inspection Status Log (ISL) and the Awaiting
Inspection Log may be inaccurate due to failure of inspectors
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to enter data on discrepant conditions.
Also, previous to the
current systems, an Erection Traveler system was used which
allowed completion credit for hangers fabricated but not
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installed.
Finding:
Substantiated, but the problem appears to have been
identified by contractor management. ~
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Discussion:
The inspector examined an example of the entry
errors noted in the Inspection Status Log (ISL) (the awaiting
inspection log is:part .of the ISL). The~ items identified
showed some erroneous entries that are of the type usually
caught by the final documentation review. The errors were, in
fact, caught by persons performing that type of review.
However, as identified in QCFRI 295'ef 7/14/81, corrections to
the ISL were not being made. The' contractor management had
not effectively resolvcd the problem at the time of inspection
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but stated they considered the problem an open one.
They had
not yet issued a procedure for final document review and
turnover but did not consider the ISL as the vehicle to achieve
that end. Based on the items reviewed, the inspector did not
have a safety concern but noted to licensee management at the
exit interview that the final review of documentation problem
had not yet been resolved, and that this problem would not be
specifically follo,ted up by NRC because of the relatively low
safety significance.
The inspector also pointed out that the UNSI QA response to
QCRFI 295 was inaccurate in that it stated difserent personnel
would be assigned the review responsibility but that action
has not yet been taken.
The inspector determined that the aspect of fabriccted, but
not installed, items being given completion credit was true
but had been documented on a Quality Finding Report (QFR-81-1&4-22).
The item dealt with foremen signing off items as complete.
personnel had not signed off the item however.
It appears,
therefore, that the contractors quality system was functioning
properly,
e.
Allegation: The as-built drawing verification may be proceeding
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on the basis of partial or sampling checks.
Finding:
Not substantiated.
Discussion: The conduct of the contractors as-built drawing
program was investigated during the previous inspection. An
UNSI stop work order had been issued on the as-built drawing
program on 9/18/81.
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Allegation: A Quality control inspector made a late entry on
a weld rod oven temperature check and post dated his signature.
Finding:
Substantiated,^but'not of safety significance.
Discussion: 'he inspector interviewed the. inspector who'made
the late entry and his supervisor. The rod. oven temperature
was satisfactory. The, inspector had neglected to sign the
checklist. The QC inspectors supervisor had subsequently
instructed him in the proper,way to make a -late entry.
The
NRC inspector did not perceive any intent to deceive on the
part of the QC inspector involved.,
g.
Allegation:
Changes to duct stendards are distributed to the
crafts prior to quality control.
Finding: Suus:. ,tiated, but not a quality concern.
Discussion: By. interview, the inspector established that
there had not been any known instances where improper inspectioris
had been performed.
It appeared, simply, that the crafts had
established a quicker distribution of changes than QA had.
h.
Allegation: There is no program of training for procedural
changes.
Finding:
Substantiated, but not a direct safety concern.
Discussion: There were no examples given where quality had
been affected.
The contractor had recently assigned a training
coordinator to improve the training.
The insper. tor did not
pursue this allegation due to the lack of safety significance.
i.
Allegation:
Personnel were instructed to work on unapproved
procedures.
Finding:
Substantiated, but this subject had been previously
identiff ed and addressed in IE Inspection Report 50-460/81-07.
j.
Other allegations / concerns were voiced by various personnel
during the course of the investigation of allegations.
These
other items are discussed below:
(1) Item:
Fillet welds have undersize throats.
Finding:
Substantiated that instructions had been issued
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which would produce undersize fillets but no such fillets
had been welded at the tine of. inspection.
Discussion:
The crafts were installing 4 by 5 inch angle
iron to HVAC duct. Due to welder access problems, the
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foreman authorized grinding an angle on the piece, thereby
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changing the intendcd fillet weld from a 90 to greater
than 90 weld. . At this point, a CNCR should have been
written since this was work outside of the procedure
(drawing DH-4563-5 and EAF 1138).
Discussions between
craft, QC, and engineering ensued and EAF 13g5 was issued
to authorize grinding the angle iron to a 60 preparation
angle (120 included angle). The EAF 1355 was issued by
UNSI engineering.
UNSI engineering is authorized by
specification 9779-216 to specify weld end preparations,
provided they are in accordance with code.
UNSI engineering
stated they had been in contact with UE&C engineering and
had discussed the problem. The EAF 1355 which approved
the increased (skewed) fillet angle was not accompanied
by a change-in the UE&C engineering document (PCP-4300A)
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which specified a fillet leg size.
Per the AWS code, the
fillet leg size should have been increased to compensate
for the reduced fillet weld throat size from a skewed
angle fillet weld.
The three observed weaknesses were discussed with the
licensee. The licensee issued a quality Finding Report
QFR 135 of Novecher 6,1981, which will ensure that
followup of the identified weaknesses is performed.
(2)
Item:
Nonconformance reports have answers by UE&C which
reference drawings not yet, issued.
Finding:
Not substantiated.
Discussion:
The inspector examined one identified nonconformance
report. The UEAC answer referenced a drawing revision
which was issued at UE&C but had not yet been issued to
the field. There is apparently a three week delay in
gettirg drawings issued to the field.
This item does not
appear to have quality significance.
(3)
Item:
procedures for concrete anchor bolt installation
disagree.
Finding:
Not substantiated from a safety standpoint.
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Discussion: .The procedure for installation of the concrete
anchor bolts requires a three turn minimum for tightening
the anchor bolts. Another procedure, the duct standard,
requires -loosening torqued anchor bolts prior to welding
on a support.
Per discussions with involved personnel on
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retightening those anchor bolts, three turns cannot be
achieved.
In.the one case this occurred, the inspector
wrote a nonconformance report.
Some QC inspectors stated
their craft people were not performing tcrque until after
welding.
The NRC inspector considered that this item did
not have safety significance.
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(4)
Item: There is no quantitative criteria for rebar damage
incurred during drilling holes for concrete anchor bolts.
Finding: Substantiated but not a safety concern as
practiced.
Discussion: Discussions with the involved perse:mel
indicated that any indication of rebar damage, that is,
any shiny metal observed, was being recorded by QC personnel
on a nonconformance report for engineering evaluation.
(5)
Item: Tack welds for fitup of permanent items are not
inspected.
Finding: Apparently substantiated, by discussion.
Discussion:
The inspector was informed by several QC
inspectors and by QA management that it was common knowledge
that none of the tack welds made for fitup of permanent
items in Unit 4 had been inspected.
It was also stated
the problem was ongoing in Unit 1.
Some of the tack
welds had been incorporated in the final weld. The
licensee was asked to investigate this item and write a
nonconformance report to document the problem for resolution.
Nonconformance report 4 CNCR-216-8 was written for Unit 4.
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The nonconformance report for Unit I had not been written
at the time of this report.
This item will be inspected further in a future inspection
and will-include the investigations of other contractors
discussed in paragraph 2.d.
Unresolved item: '(50-460/
513/81-09/01).
(6)
Item: An independent audit of the UNSI activities by an
outside audit group directed,by corporate QA disclosed
many quality findings.
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Finding:
Substantiated.
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Discussion: The~ inspector reqmted and obtained a copy
of the audit report of the National Inspection ~and Consultants
Inc. for their audit of UNSI conducted from 9/20/81 to
10/14/81.
The audit had 87 unsatisfactory findings in
278 items audited. The audit report was reviewed by the
inspector after the exit interview.
The report emphasized areas which had been the subject of
allegations; that is, numerous deficiencies in document
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control, receiving inspection, and procurement.
The
report also indicated weaknesses in control of measuring
and testing equipment and preventative maintenance.
The licensee actions taken to resolve the findings of
this audit will be the subject of a future inspection
(50-460/81-09/02).
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The general conclusion at the end of the investigation of
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allegations again;t UNSI was that although corrective actions
were underway, quality problems continued to be identified
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through allegations. The point made during the previous
inspection that the licensee's system for identifying and
correcting quality problems at the working level needed improvement
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was reemphasized.
These matters were discussed at the exit
interview and at a separate meeting with the project director
on October 22, 1981.
4.
Reactor Coolant Loop Piping Special Welding Applications
The inspector observed activities for the placement of stainless
steel cladding over two completed welds on the main coolant loop
piping. The inspector observed work, interviewed personnel, and
examined in-process recards.
During the evening shift of October 1,
the inspector examined cctivities at weld FW-08 (drawing PCS-RCS-211-1).
This was inside a 28-inch diameter reactor vessel nozzle.
Inspection
interviews including the welding operator, QC inspector, QC Supervisor,
foreman, general foreman, and the superintendent.
The welding operator, a QC inspector, and a welding engineer were
all present in the reactor vessel work location. A Diametrics
welding procedure technique sheet was available at the equipment,
as prescribed by procedure. The preheat and weld wire were as
specified by procedure.
The welder (stamp number AG) appeared on
the wold material attendant's logs as qualified for the process.
Interview of the welding operator demonstrated his familiarity with
the process and equipment, the limits of. technique sheet, and the
attention to welding heat track-alignment and rigidity.
The cladding welding had actually commenced on the evening shift of
the previous day, at which time two weld passes were accomplished.
On the following day-shift, three additional passe were placed.
Project surveillance activities apparently found that the passes
had been placed contrary to the procedure specific requirement that
the cladding passes be started against the existing pipe cladding.
This was apoarently con.sidered to be an in-process rework, and
verbal directions had been given to grind out the five passes; this
work was acccmplished. The QC inspector subsequently prepared an
inspection report documenting this action; its disposition prescribed
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a liquid penetrant examination of the ground area prior to resumption
of welding. The inspection report showed QC signature that the PT
examination had been performed.
As part of the corrective action relating to the original procedure
deviation, the welding operator, foreman, and general foreman had
attended a training session conducted by a welding engineer.
A
training handout sheet included a summary of " Major Concerns", and
described a concern for encroachment on minimum pipe wall thickness,
where grinding is performed.
It described that such excessive
grinding would need be built up with an E7018 or-70S material prior
to addition of stainless steel cladding. The welders and the
foreman appeared knowledgeable in this infomation.
(The evening
shift QC inspectors had not been invited to, nor had they attended
this training session.)
Welding had not yet started when the NRC inspector arrived. At
this time, the welding foreman raised questions with his supervision
and the QC inspector relative to an ultrasonic examination which
was verbally requested by the day-shift personnel at shift-change
time. This was categorized as an information only' test, and was
not prescribed in writing.
In the absence.of written instruction,
the QC inspector, general formean, and the Superintendent were
prepared to prcceed without the UT test.
Eventually, after referral
to the evening shift QC Supervisor, a UT test was arranged, to
check the piping minimum wall tY kness in the area where five
passes of cladding had been remc.
by grinding.
It appeared that
the work group nearly omitted the liquid penetrant test and the
ultrasonic test, due to the practice of conveying decisions and
instructions verbally.
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It appeared personnel were reluctant to document in-process typt
work errors and corrective measures, such as the above.
There was
an obvious sensitivity to management pressures regarding reprimands
and adverse personnel actions for work errors.
(Craft and supervision
demonstrated high sensitivity to management policy that two nonconformance
reports could result in employment termination.) However, various
personnel also revealed great frustration in the use of verbal
directions to accomplish work or clarify written work instructions.
At a November 2,1Q81 exit briefing, the JA Jones QA Manager stated
that increased usa of verbal instructions is planned as normal
management of i.'-pocess work. The inspector advised that the
combination of obse ved circumstances (personnel training omissions,
verbal directiots, and employee concern over documentation of
discrepancies) appears to be a weakness in the quality assurance
program. These matters will be the subject of future routine NRC
inspection activities (460/81-09/03).
During the evening shift of October 9, the inspector observed work,
interviewed personnel, and examined records for the stainless steel
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cladding work at weld FW-15 (drawing PCS-RCS-211-1). .This was
inside a 32-inch diameter steam-generator nozzle. The. inspection
included interview of the welding operator, QC inspector,.QC Supervisor,
foreman, and superintendent on the evening work shift.
It included
inspection of the equipment, review of the records where the work
was in progress.
The welding operator, a QC inspector, and a welding engineer were
all present at the work location. A Diametrics welding procedure
technique sheet was available at the equipment, as prescribed by
procedureJAJ-WPS-P1/P3-(clad)-A8-2A.
(Five lines of standard
instructions were not legible in the lower right corner of the
sheet. When the inspector brought this to the attention of the
foreman, the foreman took immediate steps to obtain a legible
copy.) The inspector verified that preheat and weld wire were as
specified by procedure. The welder (stamp number AT) appeared on
the weld material attendant's logs as qualified for the process. A
work control sheet was available and was used by the responsible
personnel; a supplement preheat log was also used by the QC inspector.
The working conditions for the welding averator we.e cramped but
accessible; they appeared adequate for J.hieving the required weld.
An air supply was provided for the welder in the confined quarters,
from a local compressor.
The inspector identified no items of noncompliance.
5.
Reactor Coolant Loop Piping Welding Material Control
During the evening work shift on October 1, the inspector examined
the bare-wire weld filler spool in the Diametrics automatic welding
machine, at the inside of field weld FW-#8, at the reactor vessel
nozzle, (isometric drawing PCS-RCS-211-1). He examined the weld
filler material forms at the work station within the reactor vessel,
and inspected the related similar material at the weld material
control and issue station.
The material was .045-inch diameter, ER-309L, as specified for the
first pass cladding welding, by procedure JAJ-WP-P1/P8 (clad) A8-2A
Revision 0.
The material was clean and clearly marked on the
spool. The material control station attendant produced the required
quality control release tag, attesting to the material -having been
found acceptable by receiving inspection, which includes a review
of material certifications. The material attendant's and welder's
records traced the material by heat number.
In addition to the specific material considered above, the inspector
also noted general use of portable weld rod ovens for E7018 type
materials, and active storage ovens at the weld material issuance
station within the reactor containment building.
Each oven was
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equipped with a thermometer, and the storage area was well kept and
clean.
Interview of the attendant demonstrated his attention to
detail and familiarity with quality control requirements.
He had a
controlled copy of the various welding procedures; the welders
interviewed and the piping general foreman all testified that these
procedures were available to them at any time at this location.
During the evening work shift on October 9, the inspector further
examined the materials and facilities and interviewed the attendant
of the welding material issue station within the containment building.
He examined the weld filler material for tags at each end, rod-oven
material separation by heat and lot number, rod oven temperature,
material general storage, and discarded material storage.
The
examination also included typical records of returned (but unused)
material, posted lists of approved procedures and dates, posted
lists of accepted material heat numbers, and the log of welder
qualifications.
No items of noncompliance or deviations were identified.
6.
Reactor Coolant Piping Weld Heat Treatment
During the evening work shift on October 1, the inspector ascertained
that the weld joint preheating was in accordance with the specification
of weld procedure JAJ-WP-P1/P8 (clad) A8-2A, for welds FW-08 and
FW-09 of drawing PCS-RCS-211-1.
The preheating was maintained by
resistance heaters, with automatic controllers and strip chart
recorder for thermocouples. The preheating controller station was
manned by a technician.
There was ongoing walnut-shell and water
blasting in the pool area above the reactor vessel, but the nozzles
were protected fron water cooling effects, on the exterior, by the
presence of plywood scaffolding and covers above the reactor vessel.
There was radio communication between the weld crews, and QC inspectors
in the reactor vesssl and the monitoring station outside.
Inside
the vessel, the welders and QC irspectors had calibrated temperature
measuring devices to determine the weld interpass temoerature.
One
welding operator appropriately stated that he made his measurements
on the last deposited weld metal, and controlled it to the 350-degrees
specified in the weld procedure.
The inspector identified no items of noncompliance, nor questionable
practices relative to preheat and interpass temperature control.
7.
Safety Related Pipe Hanger Installation Within Containment
During the evening shift of October 1, the inspector interviewed QC
inspection personnel, and examined the preparations to install pipe
hanger SGC-18-SV-1.
The inspector noted the approval status of the
installation drawing, the weld issue slip correlation to the weld
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procedure JAJ-WP-P1-13 revision 15, the material surface preparation,
and the QC inspection hold point establishment and notation.
The records showed.that the welder (WC) had been checked by the QC
inspector, as had the weld material issue slips for the 3/32-inch
type E7018 welding electrode (heat H22N5841). The electrode was
maintained in a portable rod oven, which was active and hot.
The
installation drawing was a controlled copy, and included designation
of the weld procedure, with QA review clearly marked.
The weld
record included a final visual inspection hold point. _ The control
sheet at the QC inspector dispatch station inside containment
provided for welders to mark the sheet to show that thMr weld hold
point was ready for inspection.
It appeared that the first available
inspector was dispatched, and there was not necessarily any continuity
of QC personnel assignment to any particular hanger installation.
The inspector's interview of QC personnel revealed their concern
over procedure inconsistencies and a practice of verbal instructions
being issued to clarify procedure conflicts or provide new direction.
The inspector observed that the QC personnel each carried pipe weld
fitup instruments (hi-lo gages). The inspector questioned one QC
individual relative to acceptance criteria for weld joints and
found him to be weak in this area.
The inspector observed a pipe-fitter request QC guidance relative
to pipe hanger location tolerances. _The fitter asked how for,
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axially, he could install the hanger from its design location,
without need for new installation papenvork. The two QC personnel
at the dispatch station demonstrated unfamiliarity with the criteria.
Upon referral to the procedures, they-showed great difficulty in
arriving at the acceptance criteria.
The inspector noted that the table of tolerances in the installation
procedure (JAJ-WI-010.1) indicated that some large-bore hangers
were permitted to be installed up to 18-inches axially from their
design location, without approval of the engineer.
The QC personnel
noted that the procedure requires an as-built drawing when a hanger
is moved more than 1-inch from its design location.
However, they
could not identify who performed -the as-built, who was to call for
the effort and what their (QC) role was in this process.
The QC personnel indicated .that the JA Jones procedures were being
revised.
This was confirmed by the licensee QA Manager on the
morning of October 2.
He stated that a joint Bechtel ,and JA Jones
effort was underway in this regard.
The inspector advised that the
.
personnel using the procedures appeared to have a' number of comments
regarding the applicationtof the existing procedures.
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The licensee QA Manager advised that a quality awareness program,
similar to that recentl.v put into-effect at WNP-2,' was being formulated
for the WNp-1 project.
He expressed confidence that serious employee
concerns will be exposed, such as may relate to specific procedural
incompatibilities which were not being resolved.
He also stated
that Bechtel had been instructed to broaden the cognizance of its
surveillance personnel, to increase their sensitivity to overview
type concerns, such as the above.
These actions appeared timely
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and appropriate to the circumstances found by the inspector.
The inspector identified no specific items of noncompliance.
Hexever, the matter of procedure inconsistancies and personnel
training are being identified as deserving of further review during
future NRC inspection activities (460/81-09/04).
'
On October 9, the inspector observed work in progress on the piping
bracing assemblies of the in-core monitoring system. The inspector
examined the weld record for package RCS-115-RG-112, especially for
weld N1 of Detail D-D of drawing 9779-LL-419500 Sheet 29A. This
weld was of approximately 150-degrees skewed with the wall, and was
shown on the design drawing as a 1/4-inch fillet weld (NF-5212).
(The AWS-D1.1 Code does not recognize such extreme skewed joints as
fillet welds, but rather requires partial or full penetration welds
for such configurations.) Neither the NRC inspector, nor the
JA Jones quality verification inspector present had appropriate
gages to measure the effective throat thickness.
However, by use
of a standard fillet gage, it appeared that the throat was not more
than 1/8-inch.
Neither the welder nor the JA Jones inspector
present demonstrated familiarity with the AWS criteria relating to
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skewed joints, nor could they demonstrate measurement and definitive
acceptance criteria for the weld. The weld record had already been
signed as acceptable by the day-shift quality control inspector
(symbol RW).
Subsequently, a JA Jones weld engineer showed the inspector on
August 14, 1981 UE&C document (9779-LL-419222 Revision 2), titled
" Pipe Support Details, Interpretation of Weld Symbols - All Systems".
This document showed skewed joint details commensurate with the AWS
Code. However, the weld engineer claimed to have received the
document just the previous day (October 8,1981), and he was unable
to assert that the document had any official status. A JA Jones
welding foreman later showed the inspector his copy of Revision 1
of this document, but did not know its official status.
Neither
the construction nor the quality verification personnel could show
the inspector any place where the information of this document had
been incorporated into the work or inspection procedures.
The JA Jones quality verification personnel stated that they had
been educated in AWS requirements, s'!c.h as shown in the above noted
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documents.
However, they stated that previous nonconformance
reports written against such criteria had routinely been voided by
their management.
At this time, the lead inspector prepared NCR #4883,
and stated that he planned to tag the support identified by the NRC
inspector.
He also stated that he expected the tag to be voided.
The NRC inspector also _ examined piece mark 1-RCS-(429-117/16)-6, which
is an additional member called for by design for installation in
the same support matrix mentioned above. The weld end preparation
for this member was similar to the installed member, again contrary
to the AWS and Interpretation-of-Weld-Symbol document.
On October 13, 1981 the inspector discussed these findings with the
WPPSS QA and the Bechtel QC management. He also met with them at a
followup meeting and exit summary which included the JA Jones QA
Manager on November 2, 1981. At this time, the JA Jones representative
displayed QC inspector training attendance sheets which included
the words " skew joints" as one of three topics (dated June 11, 1981
and July 9,198); however, he did not identify any inspection
technique / criteria infonnation associated with the sessions.
He
also showed the inspector an October 9, 1979 a letter to ASME which
asked if ASME had any " angularity tolerance" on fillet welds.
The
October 22, 1979 reply stated that ASME had no specific requirements
in this regard. He stated that this inquiry to ASME had been made
because JA Jones had earlier posed a similar question to UE&C, and
had received non-definitive guidance at that time. With the ASME
reply, JA Jones management had felt constrained to live with the
UE&C fillet weld symbols for extreme skewed joints, and did not
establish inspection / acceptance techniques particular to such
configurations.
At the above mentioned meetings, the attendees could not assure the
inspector that the designers had in all cases recognized that welds
would not necessarily be installed with weld throats at least equal
to those which would be achieved with standard fillet welds of the
sizes specified on the drawings.
The situation described above demonstrates the lack of appropriate
acceptance criteria for installation and inspection personnel.
For
at least two years there has been an apparent absence of clear
WPPSS/UE&C contractor guidance an quality assurance verification of
work / inspection procedures for this matter; this represents basis
for questioning the aderpacy of skewed weld joints, installed and
inspected to date by this contractor, and possibly other contractors.
This is an apparent item of noncompliance with NRC regulations.
(460/81-09/05).
8.
Unresolved Items
Unresolved items are matters about whit.h more information is required
in order to ascertain whether they are acceptable items, items of
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noncompliance, or deviations. i An unresolved item disclosed during
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this inspection is discussed in Paragraph '3.J.(5) of this report.
9.
Exit Interview
'
The regional inspector met with the licensee representatives denoted
.in paragraph 1 on October 23, 1981.
The WNP-2 Resident Inspector
l
who had perfonned backshift inspections at WNP-1/4 met with'the
licensee representative denoted in-paragraph 1 on November 2,1981.
,
The scope of the inspections and the inspectors' findings as noted
in this report were discussed.
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