IR 05000397/1982011

IE Insp Rept 50-397/82-11 on 820517-20,0607 & 0609-11.No Noncompliance Noted.Major Areas Inspected:Activities Associated w/as-built Drawing Program & Followup Items

ML20054N039
Person / Time
Site:	Columbia
Issue date:	06/25/1982
From:	Dodds R, Narbut P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20054N034	List: IR 05000397/1982011 ML20054N033
References
50-397-82-11, NUDOCS 8207150293
Download: ML20054N039 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-397/82-11 Docket No. 50-397 License No. CPPR-93 Safeguards Group Licensee: Washington Public Power Supply System l

P. O. Box 968 Richland, Washington 99352 Facility Name: Washington Nuclear Project No. 2 (WNP-2)

Inspection at: WNP-2 Site Benton County, Washington-Inspection conducted: May 17-20 and June 7, 9-11, 1982 Inspectors: 6 t-P. P. Narbut, Reactor Inspector /Date Signed Approved by: f~ <IM R. T. Dodds, Chief, Reactor Pioject /Date 4igned Section 2, Reactor Construction Projects Branch l

Summary:

Inspection during the period of May 17-20 and June 7, 9-11, 1982 Areas Inspected: Routine unannounced inspection by a regional based inspector of activities associated with the as-built drawing program and NRC followup items. The inspection involved 59 inspector-hours onsite and 16 inspector hours in the regional office .by one NRC inspecto Results: No items of noncompliance or deviations were identifie PDR ADOCK 05000397 Q PDR

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DETAILS Persons Contacted Washington Public Power Supply System (WPPSS)

+*C. S. Carlisle, Deputy Project Manager

+*R. T. Johnson, Project Quality Assurance ?Ianager

• R. B. Glasscock, Director Quality Assurance

• L. C. Floyd, Quality Assurance Engineer

• D. C. Timmins, Technical Specialist

• R. M. flelson, Project Licensing C. Foley, Engineering Bechtel Power Corporation (BPC)

• A. Mangelsdorf, Project Manager

• R. Johnson, Manager of Quality

• Headrick, Project Quality Control Engineer

• Pobtos, Construction Manager

• E. Davis, Quality Assurance Engineer

• B. Gatewood, Project Quality Assurance Engineer G. Wagner, Lead Engineer, Piping C. O. Ruud, Quality Assurance Engineer

+ H. Boarder, Quality Assurance Engineer R. Mcdonald, Senior Construction Engineer Burns and Roe (B&R)

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• J. A. Forrest, Project Directo.'

• H. R. Tuthill, Engineering Quality Assurance Manager

• J. A. Ogawa, Engineer

• G. Conn, Engineer

• A. T. Luksic, Licensing Engineer B. M. Boyum, Project Engineer C. Osborne, Assistant to Site Engineering Manager J. B. Mahoney, Group Supervisor Pipe Support R. L. Schlosser, Project Engineer Pittsburg - Des Monies Steel Company (PDM)_

D. Culver, Project Manager D. Byers, Assistant Quality Assurance Manager

• Attended exit interview May 20, 198 + Attended exit interview June ll, 1982.

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-2- Licensee Action on Previously Identified Items (Closed) Followup Item (50-397/81-03/05) PDM Corrective Action Request Procedure had Certain Omission The item dealt with certain apparent omissions in the PDM nonconformance procedure. PDM uses a Corrective Action Request (CAR) to report nonconformances at the contractor level. The procedure omissions noted and the resolutions provided by the licensee were:

(1) The authority and method for the quality control inspector to stop work was not delineate Licensee personnel stated stop work authority was provided to the quality control inspector by his authority to write a CAR. Work is required to stop until the CAR is resolve (2) The necessity to provide justification for a "use-as-is" resolution to a CAR is not delineate The licensee stated that PDM does not have authority to prc/ide a use-as-is resolution to a CAR. CAR's which require a use-as-is resolution are upgraded to ECAR (Engineering CAR) for PDM engineering review. If necessary, the ECAR is upgraded to an NCR for B&R concurrence. The

. licensee stated technical justification is provided in every case. The inspector randomly sampled five NCR's which were dispositioned "use-as-is" and found technical justification was provided on the NCR in each cas (3) Storage of permanent plant records is not specified or invoke The licensee representative stated Section 11 of the PDM quality assurance manual provided reauirements for lifetime quality assurance records. The inspector reviewed Section 11 of the PDM quality assurance manual as it pertained to records and noted no deviations from requirement (4) Responsibility to review reports for 10 CFR 50.55(e)

applicability is not specifie The licensee representative stated that programatically B&R/Bechtel review of NCR's for 10 CFR 50.55(e) reportability met reportability review requirements. Since the PDM program requires all items which don't meet specification or code requirements to be reported on an NCR, the licensee's position appears to fulfill reportability review requirement m

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-3-(5) The cause of nonconforming conditions is not required to be recorde The licensee's position on this item was that significant or recurring conditions adverse to quality are required to be reviewed by the Quality Assurance Manager who is further charged with the responsibility to determine the cause by Section 12.5 of the PDM quality assurance manual. The licensee's position appears to meet applicable requi rement (6) Controls on voiding CAR's are not specifie PDM Site Work Instruction - (SWI) No. 3, Revision A, dated April 16, 1981. Attachment 1 was revised to include voiding requirement This item is considered closed based on the licensee's action . Site Tour During a walk-through examination of the facility, the inspector noted a containment penetration with an unusual condition. Thepegetrationwas X-21 on drawing RCIC 663-35 at elevation 550', azimuth 120 adjacent to valve RCIC-V-64. Attached to the penetration's process pipe section is a flange which, typically, is utilized by the penetration manufacturer for attachment of shop hydrostatic test equipment. Other penetration assemblies had similar flanges. The flanges were attached to the process pipe portion of the penetration assembly by two circumferential fillet welds of approximately 3/8 inch leg length. The flange in question had an additional circumferential weld which had been removed by what appeared to be mechanical chipping. The removal of the weld created a rough edged (approximately 1/8" wide) crevice area between the .3/8 flange fillet _ weld and the flange. The crevice is adjacent'to process pipe weld ISI-12-16. There were no nonconformance tags attached to the piping, penetration or flang The inspector examined other penetrations at the 550' elevation and noted other removed welds on other flanges but no additional crevices created by the weld removal. The inspector examined drawing D-129 and verified the removed weld was an attachment weld for a bell housing used for the shop hydrostatic test of the penetration assembl The flange fillet welds were not required to be inspected in the pre-service examination (PSE) program per the Code Editions required by 10 CFR 50, Part 50.55a. The licensee's PSE program was conducted in accordance with the 1974 Edition through Summer of 1975 Addend Those addenda only require examination of component supports integrally attached to pressure boundary pipin The Winter 1978 Addenda changed requirements to include all welded integral attachments to pressure boundary piping (Category B-K-1).

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-4-Those requirements will affect the WNP-2 in service insoection (ISI)

program which, by the current reouirements of 10 CFR 50.55a, require ISI to be done to the 1977 Edition through the Sunner of 1979 Addend Therefore the flange welds in question will require a surface examination in accordance with Figure IWB-2500-15 during the WilP-2 ISI progra The crevice condition created on penetration X-21 will prohibit the required nondestructive surface examination. The removal of the bell housing weld forin by chipping from other penetration flanges may not provide the 1/2 inch clear inspection distance required by Figure IWB-2500-15 of Section XI of the cod This item was discussed with licensee management at the exit interview and subseauently by telephone. Licensee action on this matter will be examined in a future inspection. (Followup item 50-397/82-11/01) Ts-Built Drawings The inspector initiated an examination of the licensee's as-built drawing program for conformance to the as-built requirements contained in ANSI fl.45~ 2, ANSI N.45.2.ll, ASME B&PV Code, and IE Bulletin 79-1 . Background The lic'ensee's and B/R's procedures for as-built drawings and analysis of as-built conditions were not issued at the time of the inspection. However, the licensee had implemented a program called " status-as-builting". Status as-builting was initiated to establish the as-built condition of systems at a point in time and to analyze the acceptability of the changes made up to that point in time. The status-as-tuilt program was initiated partly in response to NRC identified items dealing with design change control and partly for statusing completion of the plant at the time the licensee was changing contractors for construction management of the projec Licensee and B/R personnel stated that the work done for status-as-builting represents a major portion of the work required for final as-builting and the information generated through status-as-builting would be used in large measure for the final as-builtina results. Therefore, the inspector examined the status-as-built progra Schedule Licensee representatives stated that as-built drawings were intended to be completed by system turnover. This included the generation of the drawing and the seismic reanalysis of the

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-5-as-built condition. Any exceptions were intended to be carried on the startup deficiency list per procedure PMI 9-2. The system

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turnover schedule shows 20-35 system turnovers per quarter through September 1983. The licensee's currently published fuel load date is September 1983.

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In regards to the current status of " status as-built review", licensee representatives estimated, for large bore piping and supports, that j 90% of the status as-builts had been submitted and 30% had been l reviewed by B/R. Regarding large bore final as-builts, none had been submitted for reviewed at the time of inspectio c. Procedures The inspector examined the following procedures related to the as-built program:

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WPPSS Inter Office Memorandum F-80-5537 of October 30, 1980 As-built Drawing Policy, Revision .

WPPSS PMI-6-6, Revision 0, large Bore Pipe and Hanger As-builting dated December 15, 198 . UPPSS draft PMI 6-6, Revision 1, As-builting Program Requirement . WPPSS PMI-9-2, System Turnover, Revision , . WPPSS PMI-9-1, Provisional Acceptance Program, Revision 1

. B/R Letter BRBEC-F-82-0637 dated February 3, 1982 Final As-Built Pipe Support Drawing i

. WBG Procedure WP-322, Revision 3, large Bore Pipe and Hanger As-builting.

! . HBG Procedure WP-331', Revision 4, Small Diameter Piping As-builtin . B/R SEI 3-2, Revision 1, Quality Class 1 and 2 Seismic Category I Pipe Support Group Design Reconciliation.

1 . Bechtel SWP-/P-P-6 Status As-builting Program, Revision 1 1 . Bechtel SWP-/P-P-2, Revision 4, Modification of Use of Isometric Revision Request . Bechtel SWP/P-P-1, Revision 2, Revision to PRR Instructions.

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. PDM Procedure AB-1 As-Built Drawing Procedure, Revision ^

The inspector observed the following main points from his review of implementing procedurei: .

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-6-(1) Generally, the as-built procedures require as-builting to be done by field engineers without quality assurance / quality control audits for accuracy. WPPSS letter G02-79-156 of September 7,1979 to the NRC in response to IE Bulletin 79-14, stated that field engineer's as-built drawings are given an additional check by the contractors quality assurance /

quality control inspectors and the process would be monitored by the owners auality assurance group. The owners quality assurance group had identified in CAR 1012 of January 29, 1982 that the review process of quality assurance has been excluded from the as-built progra (2) The Draft PMI-66 document requires field verification of as-built drawings. The PDM as-built procedure and specification and the Bechtel policy, approved by B/R, for pipe support as-builts do not require field verification. As-builts are generated by documentation review onl CAR 1486 of November 3,1980, CAR 1475 of September 10, 1980, CAR 1433 of March 4,1980 and NRC inspection items 80-08-29, 81-18-04, 81-09-02 provide examples of design and design change control problems wherein documentation reviews may not be adequate. The rationale for the absence of field verification in the face of design change control problems in certain contracts will be reviewed in a future inspectio (3) WPPSS did not have an as-built procedure issued at the

. time of this inspectio The resolution of the above items will be inspected further in a future inspectio (Followup Item 50-397/82-11/02)

d. Examination of Piping Systems The inspector randonly selected four piping system status-as-built drawing markups from the contractor files. The inspector then obtained copies of the formal status built isometric drawing and i the stress isometric drawing, both of which represent the information

provided to the designer for seismic reanalysis and as-built

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design verification. The field piping was then walked down by the inspector. The drawing attributes checked by the inspector for

support pipe welds and piping included represented dimensions,

! angles, diagramic representation, configuration of piping and supports, weld details, and item description accurac Since the status-as-

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builts did not necessarily represent work that was 1005 complete,

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obvious incomplete work was not listed by the inspector. The systems inspected and the differences between the information provided to the designer and the actual field condition are described below:

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-7-(1) Main Steam Loop A - Drawing BC/G-211 A, Revision 2, and stress isometric M200-SL31-1 and 2, Revision 58:

f . Generally, pine whip restraints (PWS) were not specifically located on the drawing .

An exception to the above, PWS-31-2A and 2B were shown mislocated on drawing BC/G-211 A, but were not located on the stress isometric. They are currently partially installed at an elevation of 555'8".

. Snubber MS-SA- The connection to the sacraficial shield wall was shown on drawing MS-SA-6, Sheet 1. The elevation shown as 556' 5 1/4" should be approximately 554'7".

. Piece 2 stiffeners on MS-SA-6'were shown as 2'-3" lon Actual measurements was 20 1/2".

. The weld of piece 2 to the sacrafical shield was shown as a 1/2" fillet all around on drawing MS-SA-6. Piece 2 was found not welded on the top or botto (2) Condensate Supply to RCIC Pumo - Drawing RCIC-658-1.2, Revision 2 and stress isometric M200 Sheet 114-1 and 2, Revision 7 . Pipe lugs were shown as 2 3/4" long on detail II of RCIC-658-1.2. Actual lugs were 5" long and 2 3/4" wid . Weld of the east end of Piece 11 to existing W14 (shown in Section AA of drawing RCIC-S3, Revision 4).

did not have flare bevel welds installed. The same weld of Piece 10, east end, was installed without fillet The drawing detail Section AA east end shows both fillets and flare bevels installed on each piec . Flare bevel welds were not dimensioned throughout the drawing H-RCIC-53, Revision 4. Other example drawings which do not have dimensioned flare bevel welds were RCIC-56, RCIC 90lN, and RCIC 902N. There was not enouth information provided to establish whether sufficient size weld had been applie . _ _ _

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-8-(3) Standby Gas Treatment Filter Unit to Contract 206 -

Drawing SGT-624-4, Revision 4

. Gasket Piece 11 on each end of transition piece 4 appears to be rubber versus the drawing description of spiral wound stainless stee . Drawing SGT-7, Sheet 1, Section A-A; welds of piece 5 to pipe were full welds rather than intermittant welded as show . Drawing SGT-7, Sheet 1, showed Diece 1 welded to the embedment with a 1/4" fillet all around. The actual weld was not all aroun . Drawing SGT-7, Sheet 1, piece 4 has additional plates welded on to achieve the 1/16" clearance with pieces 2 and 3 respectively. These additional plates were are not shown on the drawing.

. Drawing SGT-14, piece 6 was shown welded to piece 4 of SGT-7 with a 1/4" fillet all around. The actual field condition was a weld on three sides versus fou . In the field, hanger SGT-15 had an additional hanger ard pipe attached to it labaled FDR-92. FDR-92 was not shown on drawing SGT-1 . Drawing SGT-624-4, did not show orientation of velve

" top works" for valves SGT-V-4B1 and SBl as required by the specification 215, Section 158, page 6, (paragraph 3.5.1.1.d) .

. Drawing SGT-626-4 did not identify that valves SGT-V-722 and 723 are 3,600 lb/sq. in. valves as opposed to 1,500 lb/sq. in. valves as identified on the drawin (4) Diesal Oil Fill Line - Drawing D0444-1.4, Revision The inspector was unable to visually verify the accuracy of this drawings since the pipe is buried. Discussions with responsible personnel indicated the line was buried prior to performing the status-as-built. The status as-built was generated by a records revie __-- - - _ - _ _ - __ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

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-9-At the exit interview the inspector discussed the discrepancies foun Licensee management committed to determine why these items I were not included on the drawings provided to the designer and to l assess the engineering significance of the item . Exit Interview The oersons identified in paragraph 1 met with the inspector on the dates indicated in paragraph 1 The scope of the inspection and the findings were discussed as stated in the report.

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