ML20236D545
| ML20236D545 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 07/24/1987 |
| From: | Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 8707300515 | |
| Download: ML20236D545 (2) | |
Text
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.' Docket No 50-508 .
- Washington'Public'. Power Supply System P.~0. Box 968
; 3000 George Washington Way-Richland,< Washington- 99352
. Attention:' Mr.1 D. W. Mazur Managing Director q Geritlemen:
< ThahkDyou for your letter dated March 31, 1987 and your amendment dated June ;,
15.11987, informing us of your views regarding the-item which we brought to' l o - your attention:in our letter; dated February 26, 1987.. ; E Pf Your explanationsideny the apparent violation' regarding reinforcing steel clearance specifications, based upon details of design implementation of the. applicable ACI-318-71~ Code andLassociated Commentary.':The' Region V staff.has.
- reviewed your-replies and conducted additional interviews of personnel .and examinations of records during.a- subsequent June 9-19, 1987-site' inspection. j
' Based on'the additional information provided,;ft.appearsithat the.WNP-3 ;
- Engineer prepared specifications such that one' element of reinforcing steel
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clearance would be directly verified by quality control inspectors, whereas a y second element would be verified only indirectly. Direct, verification of the ' second element (one-bar-diameter cleart.cce) is a' common and desirable. additional :) opportunity to assure proper design detail; however, we consider your reply
.to adequately demonstrate compliance with the applicable' NRC regulation.
'~ Should you have additional comments regarding this matter, we would be , pleased to discuss them with you. Sincerely,
./S/
Robert J. Pate, Chief i Reactor Safety Branch s j I
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( Washington Public Power Supply System g{ED Box 1223 Elma, Washington 98541 (206) 482 442gy 9 12: 2 1 REGioy y June 15, 1987 l G03-87-169 Docket No. 50-508 U. S. Nuclear ' Regulatory Commission l Attention: . Document Control Desk l Washington, D. C. 20555 l l
Subject:
NUCLEAR PROJECT ~3 NRC INSPECTION AT WNP-3 ' IE REPORT NO.- 50-508/86-13 VIOLATION ITEM 86-13-18
Reference:
Letter (G03-87-82), P. D. Olson to NRC, same subject, dated March 31, 1987. The referenced letter included the Supply System response to the subject violation. In response, the Supply System did not agree that a violation axisted. As a result of a subsequent discussion with the NRC, the Supply System has agreed to amend the response to more clearly define the specific condition 9 described in the violation. Attached is the Supply System amended response to Violation Item 86-13-18. i
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i: 1. j 1 U.15. Nuclear Regulatory Commission June 15, 1987, Page Two G03-87-169
. .um Should you have any questions or. desire further information, please contact.me j directly. ]
n n f au . Olson . 60) l Program Director, WNP-3 ] 1 AGC/cae Attachment cc: Mr. J. A. Adams, NESCO Mr. M. F. Barnoski, Combustion Engineering Mr. R. M.- Boucher, Pacific Power-& Light Co. Mr. W. L. Bryan, Washington Water Power Co. Mr. R. E. Dyer, Portland General Electric Co. . Mr. W. J. Finnegan, Puget Sound Power & Light Co. Mr. J. R. Lewis, BPA Mr. J. B. Martin, U. S. NRC Region V Office, Regional Administrator i Mr. R.: J. Pate, U. S. NRC Region V Office
. Mr. N. S. Reynolds, Bishop, Cook, Purcell.& Reynolds Mr. D. Smithpeter, BPA Ms. R. M. Taylor, Ebasco - Elma Ebasco - New York i
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l 1 NOTICE OF VIOLATION NO. 1 l 10 CFR Appendix B Criterion V requires, in part, that " Instructions, procedures l l cr drawings shall include appropriate quantitative or qualitative acceptance I criteria for detetuining that important activities have been satisfactorily cecomplished". . The WNP-3 Final Safety Analysis Report identifies ACI-313-71 as the applicable industry standard for construction of WNP-3 concrete and reinforcing steel ) atructures. Contrary to the above, at the time of the inspection the WNP-3 construction specification for concrete installed for the reactor building, WPPS-3240-412, did not incorporate the appropriate reinforcing steel clearance acceptance criteria of ACI-318-71 Part 7.4.1 and 7.4.5, uhich require a minimum of one nominal bar diameter clear distance between parallel bars (i.e. , 1.4 inches for cize #11 bar). The WPPSS specifications allowed as little as 1.0 inch clearance, based upon 3/4 inch and less aggregate size allowed by the specifications. This is a Severity Level IV Violation (Supplement II).
RESPONSE
The Ebasco rebar design for WNP-3 includes not only the basic rebar size and Icyout, but also the detailed location and configuration required for rebar fabrication and placing. The minimum rebar spacing for this Proj ect is g:nerally governed by the maximum size of the coarse aggregate rather than by , rebar diameter. Size No. 11 rebar is nominally 1.410 inch in diameter and the ; maximum aggregate size allowed by Specification 3240-411 is 1-1/2 inches. Using the largest allowable aggregate size, the minimum spacing allowed by ACI Code paragraph 3.3.2 is 1-1/3 times the maximum aggregate size or 2 inches. The rabar minimum spacing design for this project exceeds 2 inches, which is shown cn the Engineer approved placing drawings. Specification 3240-412, paragraph 5.02 requires that the clear distance between bars shall not be less than 1 inch nor less than 1-1/3 times the maximum size of the coarse aggregate. This specification recognizes that in isolated areas it may be necessary to shift b rs to avoid interfence with other embedded items in accordance with the ACI Ctde tolerances. In these special cases, the absolute minimum spacing allowed ( is based en the actual aggregate size used, but never less than 1 inch. The commentary to ACI-318-71 states that the minimum limits (spacing requirements) were established to permit concrete to flow readily into spaces i b3 tween bars and forms without honeycomb and to assure against concentration of bars on a line that might result in shear or shrinkage cracking. The specification combined with the design drawings meet the rebar spacing , requirements of the ACI Code. e 1
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,e March 31, 1987 G03-87-82
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i Docket No. 50-508 U.S. Nuclear. Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
NUCLEAR PROJECT 3 NRC INSPECTION AT WNP-3
- IE REPORT NO. 50-508/86-13 VIOLATION ITEMS 86-13-18 AND 86-13-19
Reference:
NRC letter, Robert J. Pate to D.W. Mazur, subject, "NRC Inspection - WNP-3", dated February 26, 1987 , The referenced letter reported. the results of the NRC inspection conducted by Mr. A.D. ' Toth and C.G. Bruch on December 8-19, 1986. Two violations were identified as follows: Violation 1 (86-13-18) The WNP-3 construction specification for concrete installed for the reactor building did not incorporate the appropriate reinforcing steel clearance acceptance criteria of ACI-318-71. Violation 2 (86-13-19) Nonconforming concrete grout had not been corrected nor otherwise
-~~--identified for future rework.
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. . .Page Two'. March 31, 1987 l: " Attached is the Supply ' System approved report detailing our. disagreement-with both : violations.. Should you have any ~ questions or desire. further information,;ple contact me directly.
L aul son Program Director,'WNP DRC/st cc: Mr. J. A. Adams, - NESCO Mr.:R. M. Boucher, Pacific Power & Light Co. Mr. W. L. Bryan,. Washington Water. Power Co. Mr. R. E. Dyer, Portiand General Electric Co. Mr. W. J. Finnegan; Puget Sound Power & Light -Co. Mr. J. R. Lewis', BPA-Mr. J. B., Martin, U.S. NRC Region V Office, Regional Administrator Mr.-Rz:J. Pate,~U.S. NRC Region V Office > Mr. N. S. Reynolds, Bishop', Liberman, Cook,- Purcell & Reynolds Mr. D. Smithpeter, BPA' Ms. R. M. Taylor, Ebasco - Elma 1-__. Ebasco - New York i l l
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VIOLATION 1 (86-13-18) 10CFR50 Appendix B Criterion V requires, in part, that " Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." The WNP-3 Final Safety Analysis Report identifies ACI-318-71 as the applicable industry standard for construction of WNP-3 concrete and reinforcing steel . structures. ! Contrary to the above, at the time of the inspection the WNP-3 construction specification for concrete installed for the reactor building, WPPSS-3240-412, did not incorporate the appropriate reinforcing steel clearance acceptance criteria 'of ACI-318-71 Part 7.4.1 and 7.4.5, which require ' a minimum of one nominal bar diameter clear distance between parallel bars (i.e.,1.4 inches for size #11 bar). The WPPSS specifications allowed as little as 1.0 inch clearance, based upon 3/4 inch and less aggregate size allowed by the specifications.
RESPONSE
I The Supply System does not agree that Violation 1 is an item of noncompliance. It is the Supply System's position that tM WNP-3 construction specification for concrete installed for the reactor bci . ing (WPPSS-3240-412) does incorporate the appropriate reinforcing steel clearance acceptance criteria of ACI-318-71. ! The Supply System's position is based on the following: 1
- 1. The WNP-3 Final Safety Analysis Report (Sections 3.8.3.2 and 3.8.3.6) I identifies several codes, standards and Ebasco Specifications for design and construction of the Category I structures.
For design of concrete structures, reference to ACI-318-71 Code is made in Section 3.8.3.2.lb of the FSAR which states, "All concrete internal structures are designed in accordance with applicable portions of ACI-318-71....". For construction of concrete structures, the detailed requirements for materials, design criteria, fabrication, erection, inspection and quality compliance are described in Section 3.8.3.6.1 of the FSAR. A listing of applicable purchase specification topics, which includes Formed Concrete ! Construction, is provided in Section 3.8.3.2.3d of the FSAR. The WNP-3 l construction specification for " Formed Concrete Construction" is WPPSS 3240-412. FSAR Section 3.8.3.6.1.1 states, "The requirements for concrete construction materials are established by purchase specification compiled for the project which clearly enu...arate applicable ASTM, ACI and ANSI Standards or portions thereof". Therefore, it is evident that design and construction of concrete structures was based on ACI-318-71 and other applicable documents. - Construction of concrete structures was governed by the applicable purchase ' specifications, which included references to ACI-318-71 on a selective basis.
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.. 3 VIOLATION 1 (86-13-18) CONTINUED
- 2. Nuclear plant structures are considered special structures and involve unique considerations in design and construction which are not fully covered by ACI-318-71 Code. Both the aCI building code and its associated' I commentary recognize this fact. Section 1.1 of the commentary states, in part, "Some' special structures involve unique -problems which are not covered by the Code...".
- 3. Ebasco Specification WPPSS-3240-412 covers the requirements of conveying, placing, curing, and finishing of the concrete. It also includes formwork and placing of reinforcing steel requirements. The specification is based on industry standards including ACI-301, ACI-304, ACI-305, ACI-306, ACI-309 and ACI-318. References to the above standards are made in various paragraphs of the specification relative to which specific provisions of the standards are to be adhered to. In Paragrapn 5.0 (Placing Reinforcement) of tne subject specification, the Engineer made no reference to ACI-318 in placing of reinforcing steel, including spacing or tolerance requirements.
- 4. The Commentary to ACI-318-71 Code states, "The minimum limits (spacing requirements) were established to permit concrete to flow readily into I spaces between bars and between bars and forms without honeycomb and to ensure against concentration of bars on a line that might result in shear or shrinkage cracking."
- 5. The ACI Code allows and in special instances requires that the Engineer take exception with the provisions of the code, providing that in all cases a rationale for such exceptions is justified.
.. 6. Considering all the above, the specification requirements for minimum spacing for reinforcing steel, together with maximum aggregate size, must meet the intent of the ACI-318-71 Code, Paragraphs 7.4.1 and 3.3.2.
Accordingly, Paragraph 5.02 of the specification WPPSS-3240-412 states, in part, " Clear distance between bars shall not be less than 1 inch, nor less than 1-1/3 times the maximum size of the coarse aggregate unless otherwise approved by the Engineer." In all instances, the Engineer approved the actual size of coarse aggregate used which in combination with the rebar spacing detailed on the design drawings meet the requirements of the ACI Code.
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3 . VIOLATION 2 (86-13-19) 10CFR50 Appendix B. Criterion XV requires, in part " Nonconforming items shall be reviewed and accepted,- rejected, repaired or reworked in accordance with j documented procedures." Contrary to the above, in 1983, concrete grout on the pedestal of .the "A" Containment Spray. Pump base was identified as nonconforming to approved specifications. The' responsible organization prepared a Quick Fix Project Change Proposal, .which was subsequently marked void after incorporation into approved aesign drawings.- . At the time of the inspection, the nonconforming condition had not been corrected nor otherwise identified for future rework.
RESPONSE
The Supply System does not agree that Violation 2 is an item of noncompliance. It is the Supply System's position that the "no7 conforming condition" of .the concrete grout was properly identified and tracked for future rework. The folicwing chronological. history of Containment Spray Pumps "A" and "B" base grouting is provided for clarification: o Both Containment Spray Pumps were released for grouting by Peter Kiewit Sons, Inc. (Contract 3240-251), the mechanical contractor responsible for the pump and connecting piping installation, in August of 1982. Morrison-Knudsen (C.ontract 3240-263), the RAB civil / structural contractor, performed propri',tary grouting of Spray Pump "A" on August 25, 1982 and Spray Pump I "B" on August 26, 1982. Both grout installations were adequately documented with no resulting discrepancies or nonconformances. o The grout configuration, as placed, conformed to the requirements of the design drawing in effect at the time of placement. o In June of 1983, an Ebasco Civil Engineer noted that the grout configuration as placed and shown on the design drawing yielded a condition not recommended by Master Builders, the manufacturer of tne non-shrink grout product used for this installation. In accordance with the site design change procedure, the Ebasco Engineer, under the authority of the Resident Engineer-Civil prepared a Project Change Proposal (PCP) which was submitted to the design engineer, requesting a drawing configuration change relative to the Spray Pump grouting details. This change was subsequently approved and posted as an outstanding (unincorporated) modification to the design drawing. o In early 1983 the project was entering the present construction suspension period and most field construction activities were halted, with the exception of activities required for maintenance and preservation. As a result, the work required by the PCP was not and has not yet been performed. Contract 3240-263 (Morrison-Knudsen) is identified on the PCP as the contractor responsible for performing the required grout work. Contract 263 is presently in a long-term suspension mode with contractual provisions to complete their original scope of work in accordance with 10CFR50, Appendix B requirements upon notification of construction restart by the Supply System.
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VIOLATION 2 (86-13-19) CONTINUED o Morrison-Knudsen's Document Control System, as described by an approved MK i Procedure tracks design changes issued by Ebasco. Through this system, { MK's engineering department identifies those items requiring additional ; work based on the design change. This program is currently in suspension l but will be in effect at restart. l l During the suspension period, as during construction, Ebasco's Site Document Control System tracks design changes (e.g., PCP's and drawing revisions) and their status of issuance to the contractors in accordance ; with the Ebasco Site Procedure for Document Control. At the time of the l NRC inspection, the Document Control System computer printout indicated {' that the PCP had been incorporated into the latest revision of the design drawing and the revised drawing had not been issued to the contractor. Design changes not issued to the contractor due to the delay will be issued to the installation contractor at project restart at which time the l contractor document control system, as described above, will initiate the field work necessary to implement the design. o During the suspension period, Design Engineering has incorporated outstanding modifications to design drawings and specifications to streamline issuance of contract documents upon construction restart. As a result, the requirements of the PCP were incorporated into the drawing and will be issued to the contractor in accordance with the Ebasco Document Control Program. The referenced PCP copy marked void, was located in the Civil Document Control Station, Copyholder No. R40. The station is maintained in accordance with the Ebasco Site Procedure for Document Control. The PCP was stamped " VOID", indicating its inactive status which is per the requirements of Ebasco's QA ASME Manual (Section I-1, paragraph 4.1.2). o During a routine inspection in December of 1986, the NRC Region V inspector observed cracks in the exposed non-shrink grout on the Spray Pump pedestals and a 6" x 6" triangular outside corner section on the pump "A" pedestal that had been broken off at an undetermined time. Based on the above, the Supply System position is as follows: There is no avidence to indicate that the damage to the grout placement, as noted 'by ' the NRC inspector, was present at the time that the PCP was generated. The PCP description of problem indicates that the originator, an experienced Civil / Structural Field Engineer, recogized a potential problem with the as-built and designed configuration of the grout and proposed the change as shown on the PCP. A Quick Fix Project Change
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Proposal'is the proper document for effecting a change and/or correcting an ! error on a design document. Block 16 on the subject PCP form states that the change was made for " engineering correction, omission or error". Although the condition of the exposed grout on the Containment Spray Pump pedestals may have appeared to be a nonconforming condition to the NRC inspector, existence of the aforementioned PCP and resulting outstanding work identified against the pump foundation drawing requiring additional j work on the pedestal grout (including removal of the damaged areas) simply _ , _ identifies an incomplete work-to-go item. Therefore, a Nonconformance Report (NCR) is not warranted in this case. j I
". * ' 10LAT10N 2 (86-13-19) CONT 1NUED l
The incorporation of' the PCP into the drawing does not indicate that the required work has been performed or will not be performed in the future. The responsible contractor is, under the terms of the suspension agreement, required to implement all programs and procedures upon construction restart to assure that their scope of work is complete prior to turnover to the Supply System. Analogous to thn situation would be the incomplete status of a given bay of structural steel as of the date of work suspension. The fact that particular memb?rF shown on the design drawing are not yet installed is not a discrepant condition. The contractor is responsible for turnover of a complete system. Additionally, the project PRIDE Program (Project Review of Installation, , Documentation and Engineering) has been established for WNP-3 in part to ' assure that installation has been accomplished in accordance with the latest design revisions. PRIDE utilizes physical plant walkdowns, documentation review, design installation verification and Work package controls to establish an overall program capable of verifying installation to the latest design at the time of installation, completeness of records, and en uring that design changes are incorporated into final installation. The design installation verification portion of this program is performed prior to system / area turnover to the Owner in accordance with the Ebasco Site Procedure for System Completion and Provisional Acceptance. In addition to -providing a response to Violation 2, the referenced NRC letter also requested that the Supply System " discuss the method the Readiness Review Program will implement to assure that construction changes have been accomplished in accordance with such design revisions". Accordingly, the following discussion is provided: 1' The Construction Assurance portion of the Readiness Review Program also samples completed installation work. If an installM ion, such as the Spray Pump pedestal with an outstanding design modification, surfaced in the CAP sample for field inspections, the Review Team is required to obtain the j latest design information (including the drawing) to identify construction 1 and inspection requirements. As the repeat visual inspection of " completed I work" is performed, the uncompleted design change would be identified. 1 Follow-up investigation to determine the cause of difference between the I as-built condition and the final design would reveal the item as work to go. Such follow-up work is required by CAP Procedure CAP 6.5, Revision 3, paragraph 3.10. Further, the CAP Office informs the project in writing of work-to-go and construction-related damage items identified in its fieid inspections.
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b' j Q k.g UNITED STATES NUCLEAR REGULATORY COMMISSION s' REGION V
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' 1450 MARIA LANE,sulTE 210 Q.
WALNUT CREEK. C ALIFORNI A 94596 FEB 261987
. Docket.No~. 50-508 Washington Public Power' Supply System P. O. Box 968
.3000 George Washington Way
.Richland, Washington 99352 Attention: Mr. D. W. Hazur Managing Director Gentlemen:
Subject:
NRC Inspection - WNP-3 This. refers to the routine inspection by Messrs. A. D. Toth and C. G. Bruch on December 8 - 4 9, 1986 of activities authorized by Construction Permit No. CPPR-154 and to the discussion of our findings held by Mr. Toth with Mr..M..Monopoli and
. other members.of your staff at the completion of-the inspection,.and with Mr. Coody during subsequent telephone conferences on January 8, 12-13, 1987.
Areas examined during.this inspection are described in the enclosed inspection report. Within'these areas, the inspection consisted of selective examinations
,( of procedures and representative records, interviews with personnel,,and q observations by the inspectors.
Based on the.res r.s of this inspection, it appears that certain of your activities were ac; conducted in full compliance with NRC requirements, as set forth in the Ns' <e of Violation, enclosed herewith as Appendix A. Your response to this notice is to be submitted in accordance with the provisions of j 10 CFR 2.201 as stated in Appendix A, Notice of Violation, q With respect to item 2 of the attachshnt, our inspection findings noted as-built l conditions which did not conform to rievised design drawings. In your reply to this item, please discuss the method the Readiness Review Program will implement to assure that construction changes have been accomplished in accordance with such design revisions. , This inspection focused upon your implementation of the Construction Assurance Program aspect of the Readiness Review Program described to us in your letter of January 20, 1986. The enclosed inspection report identifies several weaknesses in the implementation of your commitments to this program. These weaknesses
- reflect upon the potential usefulness of the pending module report, as an integrated assessment of completed work. We recommend your careful consideration 4
of these matters, since results of this inspection will be considered in our final assessment of your conduct of the Construction Assurance Program Module. T pre 91m
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+ ,. Mr. D. W. Hazur 2 I In accordance with 10 CFR 2.790(a), a copy of this letter and enclosure will
- g. be placed in the NRC public document room.
The responses directed by this letter and the attached notice are not subject to the clearance procedure of the Office of Management and Budget as required' by the Paperwork Reduction Act of 1980, PL-96-511.
.Should'you have any questions concerning this inspection, we will be glad to discuss them with you.
Sincerely, 1 b- e tAA_> i
- " M obert J. Pate, Chief Reactor Safety Branch
Enclosures:
A. Notice of-Violation B. Inspection Report No. 50-508/86-13 i cc w/ enclosures: l A. D. Kohler, WPPSS-R. B. Glasscock, WPPSS L. J. Garvin, WPPSS
.h M. M. Monopoli, WPPSS P. D. Olson, WPPSS, Elma, WA State of WA.
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L l I APPENDIX A ) NOTICE OF VIOLATION Washington Public Power Supply System Docket No. 50-508 P. O. Box 968 Construction Permit CPPR-154 Richland, Washington 99352 As a result of the inspection conducted during the period of December 8'- 19, ) 1986, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, l Appendix C), the following violations were identified: ) i
- 1. 10 CFR 50 Appendix B Criterion V requires, in part, that " Instructions, -{'
procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." The WNP-3 Final Safety Analysis Report identifies ACI-318-71 as the applicable industry standard for construction of FNP-3 cortrete and e reinforcing steel structures. Contrary to the above, at the time of the inspection the WNP-3 construction specification for concrete installed for the reactor building, WPPSS-3240-412, did not incorporate the appropriate reinforcing steel clearance acceptance criteria of ACI-318-71 Part 7.4.1 and 7.4.5, which (- require a minimum of one nominal bar diameter clear distance between parallel bars (i.e., 1.4 inches for size #11 bar). The WPPSS specifications allowed as little as 1.0 inch clearance, based upon 3/4 inch and less aggregate size allowed by the specifications. This is a Severity Level IV Violation (Supplement II).
- 2. 10 CFR 50 Appendix B Criterion XV requires, in part " Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."
l Contrary to the above, in 1983, concrete grout on the pedestal of the "A" Containment Sprey Pump base was identified as nonconforming to approved i specifications. The responsible organization prepared a Quick Fix Project Change Proposal, which was subsequently marked void after incorporation into approved design drawings. At the time of the inspection, the nonconforming condition had not been corrected nor otherwise identified for future rework. This is a Severity Level IV Violation (Supplement II). Pursuant to the provisions of 10 CFR 2.201, Washington Public Power Supply System is hereby required to submit to this office within thirty days of the date of this Notice, a written statement of explanation in reply including: , (1) the corrective steps which have been taken and the results achieved; (2) the corrective steps which will be taken to avoid further items of 98 &b(0 '2p
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L noncompliance; and'(3) the date when full compliance will be achieved. Considerations may be given_to extending your response time for good cause shown. FEB 261987 gj j# fiief Dated S. p ichards Engineering S lon i l _-_______________m
U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 50-508/86-13 . Doc'ket'No. 50-508
' Construction' Permit'No. CPPR-154 Licensee: Washington Public Power Supply System (WPPSS) !
P. O.~ Box 1223 Elma, Washington 98541 Facility Name: Washington Nuclear Project 3 Inspection Conducted: December 8-19, 1986 (On-site) January 8, 12, 13, 1987 (In-office Review) j Inspector: .. A[ . A. D. Toth, Project Inspector 4- 2 /-# 7 Date Signed Consultant: C. G. Bruch, EGG Idaho Idaho National Engineering Laboratory Approved By: m///_ . Date F-X-ef7 ( .-Richar agineering Chief, crion, Region V Signed Summary: Inspection on December 8-19, 1986 and January 8, 12-13, 1987 (Report No. 50-508/86-13) Areas Inspected: Routine unannounced inspection by a regionally based inspector, and a consultant, of the implementation of the readiness review-
. program / construction assurance program for concrete work completed prior to commencement of extended construction delay. Inspection procedures 30703, i
'47051B, 47056B, 92700,.92701, and 92702 were considered for inspection "
guidance. Results: In the area inspected, two violations were identified with respect to j rebar clearance requirements of ACI-318-71 in applica.ble concrete l specifications (Reference Paragraph 13), and failure to correct identified j
' deficiencies (Reference Paragraph 14). j The program implementation did not appear to' meet licensee commitments relative to consideration of prior problems in the selection of work, samples and attributes, and in establishing that construction work procedures had implemented design requirements and were satisfactory. Implementation of statistical random sampling appeared overly simplistic and incomplete, with conclusions subject to challenge of their validity.
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.- , 1 DETAILS
- 1. Persons Contacted Washington Public Power Supply System P. D. . Olson, WP-3 Program Director
*C. E. Love, WP-3 Project Support Manager
*C; M. Butros, WP-3~ Planning & Administration Manager j
*D. R. Coody, WP-3 Project Quality. Assurance Manager
*W. K. Drinkard, WNP-3 Quality Assurance Engineer
*A. G. Carlyle, WNP-3' Quality Assurance Engineer-
*D. W. Coleman, WNP-3 Licensing Manager
*M. M. Monopoli, WNP-3 Plant Manager
*E. A. Stauffer, WP-3 Plant QA/QC Manager ]
L. J. Garvin, Readiness Reviews Program Manager j
*G. A. Block, Engineering Assurance' Manager i
*R. L. Knawa, Construction Assurance Program Manager
*T. A. McCormick, WNP-3 CAP Concrete Module Team Leader F. Teague, WNP-3 CAP Concrete Module Engineer
*N. F. Bliis, WNP-3 CAP Concrete Module QA Engineer S. Michaels, WP-3 CAP Concrete Module QC Inspector
.L. Fields, WNP-3 CAP Concrete Module QC Inspector j EBASCO j *R. M. Taylor, WNP-3 Project General Manager T *V. P. Gupta, WP-3 Site Project Engineer
;*H. Torturgul, WNP-3 Civil Lead. Engineer (ESSE)
*B. C. Bennett, WNP-3 Contract Administration Manager
*R. E. Niemi, WP-3 Resident Civil Engineer
' *P. L.' Pitman, WP-3 Quality Program Site Manager .(Acting)
Adams Associates (WP-3 Owners Group Agent)
*J..A.. Adams, Site Representative
- Designates persons in attendance.at exit meeting 9:00-10:30 AM December 19, 1986.
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- 2. Construction Assurance Program (CAP) Status j 1
The first CAP Module (C3-01 Earthwork) report was submitted to NRC i September 10, 1986 and was under final NRC review at the time of this inspection. The second CAP Module (C3-02 Concrete) report has not yet been prepared by-the licensee. The licensee CAP review plan was issued to CAP staff October 30, 1986 and the reviews were approximately 75% complete at the time of this inspection.
)
i The WNP-3 project is in extended construction deferral status, with no j construction in progress, except preservation and maintenance activities. l
' '- i 2
l The EBASCO site engineering staff level was nine (9) at the time of the.
. inspection.
3.- Background A Jul) 12, 1985 NRC letter to WPPSS accepted the licensee proposal to
. conduct a readiness review program for WNP-3 (and WNP-1). The proposed two
. phase program would address adequacy of completed construction during phase I, and all aspects of new or changed design and construction and readiness =
'for. operation in phase II. The phase I program consists of a Construction-Assurance Program (CAP) and Engineering Assurance Program (EAP).
The licensee responded to specific NRC questions.on the CAP through-a-January 9, 1986 letter to NRC, along with a revision'to the CAP. Based upon the WPPSS replies, Revision 1 of the CAP was accepted via February 25, 1986 letter to the licensee. The NRC acceptance noted that planned module report' format and content appeared to be tentative and would be the subject of further NRC insjiection and review, to determine if the licensee construction reviews provide. confirmation that completed plant construction complies with FSAR commitments and NRC regulations. The attachment to the NRC-acceptance letter noted,that the plan appeared capable of providing assessments which would ascertain whether or not all such commitments and regulations had been met. The NRC acceptance of the program recognized that the validity of the final I product would be a function of the effectiveness of the general program described. i
.. The described CAP accepted by NRC discussed detailed and in-depth reviews,
.with:
... selection of work activities based upon known or suspected licensee and/or contractor problems and industry problems;
... checklists and reviews which consider past special programs that addressed known problem areas; and
... sample selections based upon. detailed review of contractor performance history and the extent of contractor activity.
In response to specific NRC questions, the licensee also described in the January 9, 1986 response that the CAP team will: l l
... establish that (contractor procedures) implement the design requirements and would result in satisfactory construction products;-
... select known or suspected problems areas (including NRC open items) that pertain to their respective modules (e.g. concrete) which will be considered by the team in developing review plans, samples, and
' attributes for inspection.
The above descriptions of CAP consideration of past problems appeared to satisfy the NRC interest in assuring adequate licensee synthesis of individual past inspectio1 and audit results (to draw conclusions about the I l
3 1. overall extent, significance, and root causes of problems), and the effectiveness of evaluation of inspection findings (to ensure that they were not treated as isolated items to be dealt with individually as opposed to being symptoms of more pervasive underlying problems requiring broader management action).
- 4. Purpose of this Inspection The purpose of this inspection was to assess implementation of the CAP during work in progress on the Concrete module, at a time when CAP reTiew personnel were available for interview and records samples were readily available for examination. 1 The assessment was intended to provide details of the program implementation, to allow future meaningful interpretation of the report expected to be submitted by the licensee to NRC after completion of the licensee reviews, analysis of findings, and definition of follow-up actions.
The assessment was intended to identify any weaknesses in the program Laplementation which may require additional licensee actions for inclusion in the final report, or alternatively, additional NRC efforts to supplement the final report (as a basis for NRC conclusions regarding acceptability of completed concrete construction.) The inspection was heavily oriented toward assessing implementation of the licensee commitment to in-depth and detailed reviews. This included ( evaluation of:
- a. The application of a review of past known and suspected problems to the selection of work, samples, and attributes to be considered by the review team.
- b. The extent of licensee examination of contractor work procedures, especially in process controls which cannot be assessed by examination of completed construction. (Prior NRC inspection findings indicated a ,
weakness in control of contractors and implementation of FSAR l commitments in procedures.)
- c. The distribution of sample selection by work / structures, time period, and contractor involved.
- d. The selection of the populations from which samples were taken for 1 assessing particular attributes.
- 5. Inspection Approach A regional inspector consultant participated in the inspection. The consultant assisted in preparation of a preliminary list of significant elements of concrete construction, and in evaluation of overall and specific aspects of the WPPSS CAP concrete module on site implementation.
He was on site December 10 through 19, 1986.
1 l The inspector and consultant examined the CAP Concrete review plan which was issued to the WPPSS reviewers for implementation, to assess the nature of the instructions, the nature of problen, review conclusions which bad been incorporated and the manner in which procedure reviews were to be addressed. The inspector compiled a list of previously identified NRC inspection findings which NRC had not yet determined the final resolution, and reviewed the history of past inspection findings whose resolution had previously been accepted by NRC. He interviewed CAP program personnel and project QA personnel regarding the nature of the current problem review efforts and status of previously identified NRC inspection issues. The inspector also reviewed checklists and backup documentation associated with : the CAP review of past audit and surveillance reports and findings relating ! to concrete work. He examined data relative to the currently incomplete l CAP review of past nonconformance reports relating to concrete. l The consultant developed a preliminary list of significant elements relating to concrete quality. This list was used, along with a similar i list prepared by an NRC Quality Assurance Branch consultant, as a basis for examination of the scope of the licensee's review checklists. i The inspector and consultant examined nearly all of the CAP review checklists which had been implemented, or were substantially in progress, and the associated plant records in many cases. They particularly considered the sample selected compared to the amount and dates of work by , each contractor, the significance of the review attributes, the nature of j ( the population from which samples were selected, and the size of the samples. i The inspector also reviewed the status of development of plans for conducting reviews for which checklists have not been defined. !
- 6. Overview of Program Commitment Implementation The approved licensee Construction Assurance Program was to: " Provide additional assurance that there are no undetected generic quality problems I associated with the fabrication and installation work of Supply System ;
Contractors during their period of performance at WNP-3." For concrete i work, the generic limitation materialized in the selection of random samples from a population of work by all contractors involved, without specific focus on individual contractors (other than by proportionate amount of work done) and with little consideration of their individual performance histories. The NRC report of CAP program review (Inspection Report 86-01) concluded that the CAP was capable of providing an assessment which will ascertain that all FSAR conunitments and regulatory requirements have been met. Actual implementation for the concrete module is reflected in notes by a member of the licensee's Overview Committee (T. Bishop) which stated in I item I.A: " Program designed to provide added assurance (versus total verification)." A substantial FSAR review was conducted, however, the CAP matrix of FSAR Cossiitments versus Specifications and CAP Checklists showed that not all FSAR conmiitments were addressed by CAP review checklists. For l
d 5 j
)
FSAR commitments identified with a CAP checklist, the checklist often
-addressed only a part of the commitment; the checklists were notably weak in assessing commitments involving work processes which could not readily be confirmed by examination of hardware or existing direct verification j records. Little effort was directed to assure that individual contractor j generated procedures had incorporated such PSAR/FSAR requirements during j the various periods that work was. performed. The CAP efforts were, rather, ;
to consider only selected significant attributes of concrete construction which might be confirmed by recorded numerical data, or signatures on records, or inspection of in place concrete surfaces and exposed' reinforcing steel. This partial review appeared consistent with the licensee consnitment to provide assurances additional to that arising from existance of prior quality assurance programs. l The program implementation considered so.ne past problems at WNP-3 and some significant past problems in the industry, and these were noted in the review plon. However, the sample selections, individual checklists of attributes to be examined, absence of supporting documentation, and interviews indicated that the overall CAP problem review effort was minimal. During the inspection, the inspector noted that undefined additional. data analysis of .past audit and surveillance reports was planned, and a review of contractor past nonconformance reports was planned (with some trending work already accomplished). However, the undefined and incomplete status of these reviews existed at a time when implementation of the review checklists was already 75% complete, with little evidence that interim results of the problem reviews had been incorporated. The CAP management representatives also clearly stated during the inspection and exit meeting that the purpose of the CAP was not to examine resolutions of ( previous problems for adequacy, nor to effect resolution of previously l d identified open items. The extent and manner of consideration of the problem histories was not consistent with NRC perception of the intended reviews. Specific inspection findings which illustrate the above observations are presented in subsequent sections of this inspection report.
- 7. Overview of Statistical Premises A basic premise has been implemented in the CAP concrete reviews, which !
involves selection of a sample of 60 items of various types for review of , some selected attributes. The absence of discrepancies in the reviewed ' sample then was considered as statistical basis for concluding that 5% or less of the population (frorn which the sample was selected) contains such discrepancies. This promiced to provide a substantial contribution of assurance that prior quality assurance programs had functioned as intended. The licensee's stated CAP purpose of " additional assurance that there are no undetected generic quality problems" led to a random sampling program which ignored the potential differences between contractors, and considered work activities of all contractors as one homogeneous population. The premise of homogeneity implies that only deficiencies which may be common to all contractors will be assessed with the probabilistic confidence described in the CAP review plan. Similarly, the random sampling approach I-1 l l
1 6 ldid not' consider the variance in contractor performance with time, and-again presumed a' homogeneity in the work activity population. The validity of the homogeneity premises appears questionable, in view of
. variability of individua1' contractors and time dependence of.the following:
- Individual quality assurance programs, Individual management systems effectiveness,
- Individual procedures approaches, and-Individual problem histories with time.
The licensee indicated-a great deal of confidence that.the differences between contractors was minimal in view of EBASCO having reviewed each I contractor's procedures for compliance with commitments, and in view of the- ! existence of audit and. surveillance overview programs in effect for each ; contractor. However, the inspector'noted that a cursory review of WNP-3 ] problem histories shows that early internal audits and NRC inspection 1 findings ~both had challenged the effectiveness of licensee control of 4 contractors, effectiveness of procedure reviews, and effectiveness of contractor internal programs to control quality. One contractor was determined to have inadequate training.of QC inspectors and an inability to identify and correct internal work control problems. These issues appear to undermine the basis for the licensee confidence, particularly-in view of absence of concerted CAP effort to ascertain the effectiveness of related' prior corrective action programs. A sampling approach which addresses each contractor's work'as a separate population, and which considered time periods of good and known or suspected poor performance, would seem more (,. appropriate. In two cases the licensee premise did appear to be valid with respect to selection of contractors, but not necessarily with regard to contractor performance history in time:
- a. Assessment of the concrete batch plant operations, which provided concrete to all site contractors, and
- b. Assessment of the concrete testing laboratory, which provided testing i services to all contractors.
On the other hand, concrete and reinforcing steel placement, curing and other related activities were performed by at least four different contractors with different performance histories. To illustrate the vulnerability of improper assumption of homogeneous population, one may consider the evaluation of a contractor who had a known poor performance history during a specific time period. The work activities of this contractor over the period in question may be considered the population to be sampled. The fundamental Binomial Probability ~ Distribution sampling approach (referenced by the licensee) would dictate a sample size of 60 activities; absence of defects in this saarple would theoretically ascertain less than 5% defects in the population of activities, with a 95% confidence level. But when the CAP considered similar work activities of several contractors as a single population, the CAP sample of 60 items from this population resulted in only a few selected l
for the aforementioned contractor for the questionable. time period. It is difficult to conclude that this few items would provide the same conclusions as the aforementioned 60 samples specific to that contractor and the troubled period. It would seem that a higher defect rate, or a lower confidence level may result, (presuming that not all contractor activities were homogeneous). In view of the above, it appeared that some of the concrete module sampling I plans did not include representative samples (as suggested by Sections 5.1 and 6.0.A and .B of the NRC accepted January 1986 Construction Assurance Program Plan.) The licensee actions on this matter will be considered during-the future review of the pending CAP Concrete Module Report. 1 Follow-up item 86-13-01. !
- 8. Overview of CAP Concrete Module Review Plan The review plan for CAP Hodule C3-02 (Revision 0) was approved by the CAP Manager on October 30, 1986. The plan described contractors and their period of involvement in concrete work, and the amount of concrete work performed. It briefly described results of a review of past WNP-3 and industry problems and mentioned several NRC past inspection findings.
(e.g. item 79/10-03, missing douels, was noted and a cueck for missing dowels was included in a checklist for walking down exposed concrete blockouts and other unfinished work having exposed reinforcing steel). The plan included 29 short checklists for conducting reviews, and mentioned several other reviews which were to be performed (checklists or actions plans were not included). A general discussion of the random sampling ( approach was included, as was identification of sample selections. A matrix of FSAR commitments was included, identifying implementing specification paragraph numbers and identifying CAP checklists which addressed the general subject matter. A copy of each of the 29 checklists and instructions was included in the plan. Qualifications of the review team were also described. The review plan appeared to be an accurate description of work to be performed by the team, and a record of preparatory activities conducted prior to commencement of the reviews. However, the review plan was imprecise in cross-referencing some prior CAP modules, which indicated a need for the review team to specifically consider the content of referenced prior modules relative to the current module under review. Examples identified by the inspector included the following:
- a. The C3-02 plan mentioned that Module C3-01 had included review of Batch Plant Scales and equipment calibrations. However, the C3-01 review was associated with soil-cement Earthwork, and the period of work considered did not encompass the full period that concrete activities L were performed at WNP-3. (The team leader stated that he would respond to the inspectors' concern via preparation of a new checklist number 30, which would consider batch plant calibrations for concrete work j l including water meters and admixture dispensers.) Follow-up item !
86-13-02.
- b. The C3-02 plan mentioned that Module C3-01 had included a review of the EBASCO Site Surveillance Program for contractors. However, a review of l
l
.. 8 m .- ,
the reports'showed that few of the reports related to concrete-- construction. See paragraph 12.d for additional detail regarding this item. The review plan did^not currenty address the impact on concrete work, of activities which had been deferred for consideration during future modules. Examples identified by the inspector included the following: Concrete Anchor. Bolts - Evaluation of anchor bolt installation was ! deferred for consideration in several future modules. However, hole drilling for, anchor bolts has potential for damage to concrete i reinforcing steel. Acceptability of completed concrete work cannot be . fully ascertained without assurance that anchor bolt drilling was ! performed under well controlled procedures. Follow-up item 86-13-03.
- Embed Plates - Evaluation of embed plate installation was deferred for consideration in the future structural. steel module. However, difficulty of concrete consolidation and field changes for reinforcing steel interferences could affect the integrity of the concrete in the 4 vicinity of the embeds. Acceptability of completed concrete work in I such areas cannot be ascertained without assurance that complex embed plate installations were performed. correctly. Follow-up item 86-13-04.
The current review plan did not provide details of action plans for special reviews-described in the review plan. Contribution of these efforts to assurance of concrete quality, and resolution of concerns expressed
.elsewhere in this report, could not be assessed by the inspietor in the
( following areas (CAP treatment of these areas will be examned in future NRC reviews):
- NCR Review - An engineering review of nonconformance reports was described. The nature of this review and planned use of findings was undefined. (Some licensee effort had been made to categorize the past NCRs, but the review was described as not yet complete. F paragraph 12.e for additional details regarding this item.
- Trending of Compressive Strength Tests - The nature of this proposed review was not defined. Follow-up item 86-13-05.
- Review of Correlation Data For Truck / Pump Sampling Points - The nature j of this proposed review was not defined. Follow-up item 86-13-06. J
- Statistical Analysis of Rebar Tensile Test Results - The nature and extent of this proposed review was not defined. Follow-up item !
86-13-07.
- Statistical Analysis of Cadweld Tensile Test Results - The nature of this proposed review was not defined. Follow-up item 86-13-08.
- Review Construction Manager Actions Relative to NRC/QA Activities - The nature of this proposed review was not defined. Follow-up item 86-13-09.
1
~
l
- Review of Applicability of IN-83-40 (relating to environmental l l
qualification of epoxy grout) - The nature of this proposed review was l not defined. Follow-up item 86-13-10.
- 9. Review Plan Omissions-The inspector judged that' the following matters were of interest to the NRC-assessment of concrete adequacy, but were not included in the CAP Concrete Module review plan:
- a. Core Drilling - Consideration of the potential impact of core drilling activities on'the adequacy of installed reinforcing steel. Follow-up item 86-13-11.
- b. Bending of Reinforcing Steel - Consideration of past known problems - )
with proper bending of reinforcing steel. (However, the exposed-rebar ! walkdowns planned by the. CAP do include. inspection for cracks in exposed bent bars.) Follow-up item 86-13-12.
- c. Grout Walkdown Inspections - Visual assessment of installed grouts to-determine evidence of cracks, proper thicknessi filling of cavities',
and evidence of distress. (The inspector obser=ed cracks in non-shrink ( grout on safety related pump pedestals.) Follow-up item 86-13-13.
- 10. CAP Concrete Review Team Personnel Qualifications-The review plan description of personnel qualifications, and interviews of
( individual team members showed that management, civil engineering, quality assurance, and civil discipline quality control inspection capabilities had , been adequately incorporated into the team. The personnel appeared I qualified to perform their respective duties. l L 11. Overview of Significant Elements Review The licensee compiled a listing of elements which which can affect concrete' ' and grout work quality. This included materials, installation, tests, and inspection attributes. These were then prioritized to reflect those which had greatest impact on quality and which could be readily assess ed through a review of existing records. The prioritized elements were then incorporated into checklists for the review of records and hardware. Many elements, important to obtaining adequate concrete, were not selected for direct incorporation into review checklists, particularly where such items could be indirectly inferred through test results on completed work. For instance, various batch plant materials controls and materials tests were considered indirectly via review of concrete compressive strength test results for concrete that was placed into the structures. This approach placed a great deal of reliance on the validity of test results, and was accordingly. augmented by review of test equipment calibration and control and test personnel qualifications. The resultant CAP checklists and special review topics were considered by the inspector relative to a similar preliminary list of important elements prepared independently by NRC consultants. Both lists were-derived from l
-______-________0
10 1 consideration of ACI and ASTM standards applicable to concrete construction of nuclear plants. The basic CAP listing appeared generally comprehensive. The licensee prioritized and abbreviated this basic list. The abbreviated list did not address some areas of NRC interest, as noted elsewhere in this j report. A more critical evaluation of the the selected elements, and the .i associated nature of reviews of each element, will be reported after CAP l completion of reviews, special studies, and the final report. I
- 12. Problem History Reviews The inspector found that the CAP review preparation included limited review of past problems at WNP-2 and other nuclear facilities. In some cases the subject of the problems was included in CAP concrete review checklists, although there appeared to be little evidence of root.cause analysis and focused probing to assure that the problems had been resolved and nonrecurring. There appeared to be no synergistic evaluations of past !
problem records to assure that work process weaknesses were isolated and i not indicative of a need for more general management action which may not have been recognized and taken. The CAP management stated that the CAP purpose does not include assessment of the adequacy of disposition of previously identified problems. The absence of a comprehensive evaluation i of past problems and contractor performance history does not appear consistent with the Sections 6.A and 6.B of the NRC accepted January 1986 ' Construction Assurance Program Plan. The following are the results of the inspector inquiry into various limited i problem reviews which were conducted by the CAP team; identified follow-up j ( items will be considered by NRC during future review of the pending CAP ! Concrete Module report:
- a. NRC Previously Identified Inspection Findings s
The licensee /EBASCO quality assurance staff stated that action on certain previously identified items appeared to have been completed, ; but had not yet been verified by the QA department (e.g. 81-08-03, 81-08-04, 81-09-02, and 82-06-01). The CAP management stated that the CAP purpose did not include closing prior issues, and such issues were not evaluated by CAP. These items involved quality assurance program aspects which could impact quality of construction, such as item 81-08-03 relating to ineffective engineering review of contractor work procedures. Although it appeared appropriate for the CAP to defer action on hardware problems requiring future engineering / construction forces to correct, it did not appear appropriate to defer inquiry into the status of corrective actions on program matters which could have affected quality broadly.
- b. Licensee Reported Construction Deficiency Reports (50.55.e)
A cursory review of the CAP office copy of the 50.55.e index showed notations and handwritten summary sheets indicating CAP staff cognizance of concrete related prior significant construction deficiency reports. However, there was no evidence of CAP analysis of prior reports of quality breakdown and effectiveness of corrective
- _ _ _ ___ _ . _ _ _ _ _ _ _ _ _ _ = _. __
i
,1+
. -, '33 actions. Report number 35 involved-significant concrete voids in the l auxiliary building and corrective actions. Report number 25 involved 1 cracks in welds of embed plates. The CAP efforts did not appear to )
have elements to address satisfactory resolution of the generic I elements of these items. k The deficiency described in report 25 involved a vendor (Fought Company):
- Use of-partial penetration welds where full penetration welds were required,
- Failure to perform specified post weld heat treatment,
'. Failure to identify and reject assemblies with' cracked welds.
I The final documented corrective action available in the licensee /EBASCO l QA department stated: { All specific hardware items have been corrected. j
' Training of Vendor Quality Assurance Representatives completed a
*- Vendor. surveillance inspection plans revised to include appropriate- {
inspection requirements. ! These actions did not appear to address the generic isiplications of the ( inadequate vendor quality control, inadequate vendor surveillance training and checklists for other similar procurement. .In' absence of other documentary evidence to support such generic issue, the licensee 1 actions appear to have been incomplete. Since the CAP reviews of embed plates has been deferred to a future module, this item remains open pending completion of licensee reneric actions. (Item 81-05-H).
- c. Construction Manager Records vf Audits of Cor. tractors l The CAP. review activities considered audit team qualifications, audit ,
planning and preparation, documentation and follow-up of findings. The CAP checklist (CAP-D-GC-02-27) required assessing appropriateness and j timeliness of corrective action, including stated actions to prevent l recurrence. The CAP reviewer was required to attach copies of all audit findings to each completed checklist, for information of the team leader during his review of the completed checklist. The inspector examined the concrete related aspects of CAP completed checklists and attached audit findings for WPPSS/EBASCO audits of contract #265 (J. A. Jones Company) numbers 265-1 through 265-7; these . involved an audit period of April 1980 through August 1982. The i' checklists noted acceptable audit performance with respect to the checklist criteria. The review was completed by the reviewer on November 5, 1986 and approved by the CAP manager December 8, 1986. The )
; CAP manager stated that analysis of the audit review data was not yet !
complete, et the time of this inspection. The records reviewed by the l CAP show that an aggressive audit program was in effect by WPPSS/EBASCO j t
M+' 12
,?
during concrete work activities. However, it does not appear that CAP checklists for-concrete activities have incorporated elements to ! specifically address certain known and suspected quality . i assurance / quality control problems revealed by such audits for contract
#265 activities between start.of work in January 1980 through November 1981. Neither sample selection nor,special reviews address the validity "
of contractor records and work quality during the period of the contractor's unwillingness to acknowledge deficiencies in quality control inspector knowledge and training and. internal audit i effectiveness. (The auditors had found demonstrated knowledge j deficiencies in methods of concrete consolidation, installation of 1 reinforcing steel, layout of concrete delivery equipment, and methods of checking vibrator frequency. Several of the current CAP checklists rely upon QC-inspector signatures as evidence of satisfactory compliance of these items.). This issue had remained unresolved for the period October 1980 through November 1981,' involving slowly escalating management attention culminating in a WPPSS/EBASCO August. 1981 issuance of a show cause order to the contractor. The CAP reviewers appear to.have relied upon the fact that the audit findings and manages.ent corrective action request (CAR) were subsequently
" Closed by WPPSS/EBASC0; independent CAP review apparently was not made to assure that appropriate evaluation of prior work had been conducted as part of the closure process. Additional CAP attention appears warranted to evaluate concrete work performed during this troubled period. Follow-up item' 86-13-14.
- d. Records of Construction Manager Surveillance of Contractors
( In addition to periodic audits of quality assurance programs of each contractor, WPPSS/EBASCO conducted a program of quality assurance surveillance of each contractor. On a daily basis, quality assurance personnel would visit various contractor work activities in progress ! and observe conformance to program requirements. A daily report was prepared for each such surveillance, and the CAP reviewer determined that the logs showed 7346 such reports were generated. Through random number generation, the reviewer selected 60 random surveillance reports as a sample. The sample included 6 of the 681 reports for the contract
#265; oxay three (3) of these involved concrete work; similarly, one of 120 reports for contract #216, one of 96 reports for contract 219. The CAP review of these documents was conducted using checklist number CAP-D-GC-01-16, and was completed June 18, 1986 in conjunction with the first CAP module (Earthwork). Review criteria consisted of verifying existence of the report identified in the log, determining if the surveillance report contained approval signatures, and ascertaining that the recorded discrepant observations contained notation / record of follow-up and resolution. This review did not include efforts to detect and evaluate trends for concrete quality, but rather were oriented toward ascertaining that a project wide surveillance program did exist, surveillance were performed and documented, and mechanisms exercised to resolve identified specific discrepancies; thus the absence of emphasis on concrete work, and consequent little value in assessing adequacy of concrete work. Follow-up item 86-13-15.
I
g.. 13
- e. Nonconformance Report (NCR) Records 1
The CAP reviewers utilized the existing project nonconformance report trending system to obtain a printout of c,acrete related NCRs, grouped 3
.by type of deficiency. At the. time of this inspection, the CAP review 5 and analysis of this data was not complete. There was no definitive- 1 analysis to identify which of the NCRs were prepared by contractor QC inspectors prior to final QC acceptance of work, and which were' i prepared after final acceptance of the work. The inspector noted 200 J NCRs categorized as missing reinforcing steel dowels, but the i significance of this could not be ascertained without review of the I individual NCRs for specific discrepancy, time period (repeatedly occurring?), and noted generic corrective actions. This observation i was typical of several NCR categories e.g. see paragraph 15.f.regarding batch. plant review. Since the implementation of CAP checklists-was about 75% complete at the time of this inspection, it appeared that a detailed consideration of the results of the NCR review had not been incorporated into the concrete CAP review. The CAP staff did not identify any currently specific plans for completing the NCR review nor "
method of application of findings. Follow-up item 86-13-16.
- 13. Nonconformance Report Examination For the subject of missing dowels, the CAP checklists include review for a signature that replacement inspections were accomplished (including rebar placement); also one checklist includes a walkdown of exposed steel in blockouts and incomplete placements; the inspector did
( not consider these to be a thorough exploration of this issue. Other data bases, such as old construction photographs, sketches on field changes and nonconformance reports, and other in process documentation ; would appear to offer the opportunity for a more thorough assessment of j reinforcing steel placements. The inspector examined one such NCR (No. 1 265-3845 and related 3864), for contract #265, which identified { concrete void problems in the reactor building shield wall. The voids j occurred in an area of congested reinforcing steel and involved areas i about 8 feet wide and 1 -1/2 feet high at both the inside and outside faces of the 3-foot thick wall. The NCRs included detailed sketches of the discrepant areas after excavation to sound concrete; the sketches showed rebar patterna in an apparent discrepant configuration. The rebar clearance criteria of ACI-318-71 and construction specification WPPSS-3240-412 had not been achieved (more than 1-inch clearance i between bars). This appeared to be a contributing factor in the l resulting concrete voids from ineffective concrete consolidation during placement. The void was still exposed in the field, and inspection showed inadequate clearances. Although the actual field condition varied somewhat from the NCR sketches, the representation of inadequate l clearances was clearly valid. Further review showed that the construction specification did not implement the ACI-318 Part 7.4.1 and 7.4.5 requirement for one nominal bar diameter clear distance between parallel bars (the specification called for minimum of 1-inch spacing). l [ l.w _ _ _ __ -
- t , ,
g.b , j4; j
- j i
.The. original inspection and acceptance of the reinforcing steel
'" spacing / orientation" was documented on the Concrete Replacement Checklist Record for Blockout F2'and F3, dated February 4, 1982; no discrepancies'were noted. -The NCRs which documented the concrete void !
repairs.were dated by the EBASCO Resident Engineer office November 29,
'1982/ October 25~, 1982; there was no evidence of identification and evaluation of the discrepant rebar clearances shown on the NCR I sketches. The inadequate specification, the nonconforming rebar installation, and the failure of project personnel.to. recognize and L correct the nonconforming installation appear to be violations of FSARL commitments and regulatory requirements. However, this item would be cry sted to be identified by the CAP reviewers during the rebar., :
walkdowns, yet to be conducted (detailed checklists have not yet been ! prepared). Follow-up item 86-13-17. l 1 The failure to incorporate appropriate quantitative acceptance criteria into the construction specifications appears to be a violation which~ ! would not necessarily be identified through the CAP process, which j
. commences with the presumption that such details of the specifications i are correct. (Such discrepancies are not necessarily identified through the Engineering Assurance Program, which only samples specifications.to arrive at probabilistic determination of acceptability of all contractor specifications.) Violation item 86-13-18.
- 14. Field Inspection of Concrete Grout The inspector visually examined the grout placements at safety related equipment in the reactor auxiliary building: Diesel Generator 1, Auxiliary ,
Feedwater Pumps, and Containment Spray Pumps. Minor cracks were observed 3 in several area. Particularly noteworthy were cracks.in the non-shrink grout on the pedestal of the containment spray pumps. These cracks radiated outward from the base of the pump-and it could not be readily l detensined if they extended under that base. These cracks were through the 3-inch thick grout layer, and at pump "A" a triangular piece (6" by 6") had , broken off and was missing. The opposite corner showed a small piece broken off and clear evidence of lack of bonding along the surface of the chamber of the supporting pedestal. The placement records designated " Proprietary Non-shrink Grout", and indicated that Masterflow 713 (Non-metallic, Non-shrink) had been used. l Acceptance of surface preparation and pre-soak were indicated by QC j signatures on the placement records. Specification WPPSS-3240-470, Section 4, defined required grout materials and properties to be demonstrated by l qualification tests. Part 4.02.I required testing to demonstrate i proprietag non-shrink grout (cast in a 4" by 6" by 6" block) "not develop any cracks on the surface nor shall it have pulled free from the form at the sides". The observed through-cracks in the grout on the containment spray pump pedestals appeared inconsistent with such qualification, and lack of bonding reflected improper surface preparation. During the
. inspection, the project QA department could not produce any evidence of prior identification and planned action regarding this discrepancy. During i a subsequent January 13, 1986 telephone conference, the licensee identified l to the inspector the existence of Quick Fix Project Change Proposal i
+ 15 PCP-19254 (originated in 1983). This document identified the damaged grout and noted that the grout manufacturer did not recommend such grout for the pedestal configuration for which it had been used. The PCP called for rework of the installation; however, the PCP had been stamped " VOID", since it had been subsequently incorporated into the design drawings in accordance with procedure. With shutdown of construction, the contractor never implemented the rework, such that the deficient condition still existed December 13, 1986. The licensee stated that there was no PCP work I
status tracking system which would assure that the void PCP would be implemented. However, the licensee stated that eventual as-built walkdown i activities would detect the discrepancy in the future. Ttt reliance on a final as-built activity, in lieu of a nonconformance control system, appears contrary to QA program requirements to maintain identification of the acceptability of items and to control the identification and rework of nonconforming items. In the above case, the
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nonconformance is clearly not identified nor under control and relies upon future special activities for detection of completed work which is not in accordance with latest design. Failure to identify and correct the discrepant condition appears to be a violation of 10 CFR Appendix B quality assurance program requirements. Violation item 86-13-19. This finding indicates the need for the CAP to include grout walkdown elements in the program, in addition to the records reviews currently underway. See paragaraph 9.c, above. ('- This finding also indicates that the general as-built condition of the plant may in some respects not be in accordance with the latest revisions of design drawings. Work may thus not actually be considered complete l until as-built walkdowns are conducted to identify discrepancies, and implementation of construction to correct discrepancies (e.g. the PRIDE i program mentioned in the CAP program plan). However, this is not a l significant concern for concrete reinforcing steel and embeds, since pre-placement inspections for concrete apparently included verification of ; conformance to both the latest drawings and interim design change documents { (e.g. PCP's). This item will be considered during NRC consideration of {' future readiness review modules and at the restart of construction.
- 15. Findings Regarding Specific CAP Checklists The inspector and consultant reviewed specific CAP checklists relating to concrete and grout work, and with the following specific comments:
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- a. CAP-D-C-02-01, 02, 04, 07, 08 and 09 (Compressive Strength, Delivery, Slump and Air Tests, Replacement Inspection, Post Placement Inspection and Repairs, and Curing Inspection)
A detailed review was made of the data used by the Licensee for one of the 60 samples. A step-by-step review of the process used and the data viewed was made for a second sample with the Licensee reviewer. A third sample was given a cursory review. All of the data examined by I l l 1
..,m - , . - _ ,
1 ,V** , 16 i the' inspector, and the response of the Licensee reviewer were I acceptable. , A few cracks in the concrete were noted during the walkdown observation for Licensee checklist 21. These did not appear to reflect an abnormal ; zamount of cracking. Some cracks showed efflorescence which indicates ' that they are flowing water. It is considered that this should be added to Licensee checklist 28 (Preventive Maintenance) or reviewed separztely for potential rebar corrosion. Follow-up item 86-13-20. i
- b. CAP-D-C-02-10 (Cement Tests)
A spot check of the data within the Licensee sample of 60 was made and did not disclose deficiencies in specified requirements. ;
- c. CAP-D-C-02-11 (Alkali Reactivity and Abrasion Resistance Tests) !
The data within the Licensee sample of 60 laboratory tests for both f alkali reactivity and abrasion resistance was spot checked. Additional ) examination was made of.the actual laboratory results of 35 aggregate reaction samples representing fine and course aggregate dispersed over I the period of July 1978 through February 1983. The results of each test were verified on the Figure 2 plot from ASTM C289. All but one set of results plotted well into the zone of " Innocuous Aggregates" based on reduction of alkalinity. The one exception was borderline i between innocuous and potentially deleterious. It was noted that the numerous petrographic examination reports listed the need for the ASTM (- C289 reaction tests due to a significant chert content in both the { Steilacoom and Weyerhauser aggregates. The C289 tests indicated low J reactivity. In addition, low alkali cement was used. The licensee's l conclusion of no expected alkali-silica reaction was supported by the 1 data examined. I
- d. CAP-D-C-02-14 (Rebar Tests)
A detailed review was made of the data compiled by the licensee for the sample of 60 rebar heat numbers. All but one heat was above , requirements for elongation, yield and ultimate. The one exception was l reviewed. The slightly less than specified yield had been ) dispositioned in an acceptable manner. 1
- e. CAP-D-C-02-15 (Cadweld in-Process Testing) 1 A detailed review was made of the data compiled by the licensee for the j sample of 60 cadweld strength tests. All results met or exceeded l specification requirements. The sample dates were reviewed and I verified as reflecting a broad range of time. ;
l This instruction only requires review of tensile test results of a random sample of 60 cadwelds of those which have been tested. Thus, it would not detect failure to perform qualification testing of cadweld crews, nor does it ascertain achievement of proper frequency of test splices (as shown in the logic diagram of the CAP review plan page 16). The checklist does not ascertain that cadweld inspections were L
j .e t 17
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l accomplished for cadwelds and that inspection results were acceptable. .j Follow-up item 86-13-21.
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- f. CAP-D-C-2-19 (Batch Plant Certification)
This.checklistirequired CAP reviewers to ascertain that NRMCA .
inspection checklists.were completed and were signed by a registered engineer every two years.
The licensee's review of.the seven batch plant checklists was examined. Each; checklist was' intended to be. valid for two years. Four had been filled out for the main plant and three for the standby plant. One'of the actual checklists was reviewed in detail. It. reflected acceptable-data with the exception of hot water heating capacity. That had been resolved during additional. review. 'Also, this did not show up..as low temperatures in delivered concrete during the review under licensee checklist 02 (delivery). 7 Neither this, nor other CAP concrete checklists, appeared to call for verification of performance of mixer uniformity tests,- daily /_ weekly / monthly batch plant inspections, truck water meter calibration and evaluation of' records of disposition of identified discrepant conditions' arising from such inspections. These elements . provide the assurance that batch plant operations were uniformly-
' controlled so as to represent a continuous process for which production statistical-sampling approaches would be valid. -The CAP manager stated
,.. that a new checklist CAP-C-D-02-30.(see paragraph 8.a) would address , {
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weighing and dispensing equipment in the batch plant, including. water meters and admixture dispensers, y < The inspector examined files of daily / weekly / monthly quality control ',' 'c0
. inspections and noted extensive records of monitoring by the batch r plant contractor quality control inspector.and quality control personnel of the independent testing contractor. A minor discrepancy -
was.noted in the manner of disposition of a discrepancy in the calibration of batch plant-temper water scales in the 1978-79 period. This appeared to be of no consequence, but was directed to the . attention of the: CAP reviewers. Also, the NCR categorization analysis showed multiple NCRs relating to batch plant operations (status indicated as closed); final conclusions regarding batch plant adequacy may need to consider an analysis of the implications of that data base (e.g. repeated significant findings). See paragraph 12.e for additional detail regarding thistitem,
- g. CAP-D-C-02 20 (Cement Storase)
The licensee check of the sample o'f.60 cement storage inspections was reviewed. The sample reflected a broad range of dates for the two plants and did not disclose deficiency information. a 4-L ~ v y-
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.h. CAP-D-C-02 21 (Field Walkdown) 4 The team performing field walkdowns was observed for approximately two hours. The work noted during the course of this observation appeared- )
to be acceptable, q
- i. CAP-D-C-02-25 (concrete Inplace Strength Tests) J The licensee's' work on this checklist was incomplete at'the time of this inspection. The rebound hammer investigation had been completed and the report thereof was examined. The inspector identified aspects of additional inte est to the NRC reviews as follows: (Follow-up Item 86-13-22)
(1) The standard deviation numbers listed for hammer rebound results were not translated into meaningful information such as an indicated strength range to supplement the average indicated strength. (2) The compression test results were not correlated with the 28 day ; cylinder breaks for the concrete actually cored in Unit 5. This ' would have established a strength increase factor which could be used for the indicated results at Unit 3 to correlate the rebound and 28 day cylinder data. (3) The consultants report did not., list all report data called for in ASTM C805. ! i ' (4) The competence of the consultant and machine should have been established by correlating the rebound data with the compressive 1 tests for the cores. The range of certainly of the results should be established.
- j. CAP-D-02-26 (Concrete Block Construction)
This instruction requires review of safety related work which was originally designated as Quality Class II. It calls for review of documents "if they are available. Absence of records is not a defined criteria for a negative finding." With such an ambiguous criteria, it ; is not clear how a statistically valid conclusion of acceptability or reject can be accomplished. Iollow-up item 86-13-23.
- 16. NRC Records Examination in Addition to Licensee CAP Effort The inspectors examined the following records and made examinations which l had not been addressed by the CAP Concrete Module Checklists:
- a. Concrete Pump Correlation Data The file of concrete pump correlation data for temperature, slump and entraired air was reviewed. The data wa:: found acceptable and found properly used in the delivery QC checklists for several placements.
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- b. Mix Designs 1 l
Records were examined i.o verify the licensee's use of the specified mix design in batching concrete. Mix design 5103.75 was . selected because if appeared frequently in the sample of 60 placements selected for several of the licensee checklists. A review of eight individual batch tickets distributed over an 18 month period showed consistent use of the designed mix proportions with the exception of the air entraining admixture. This was reduced in later batches but did not lead to unacceptable entrained air in the delivered concrete.
- c. Aggregate Gradation ,
Records were spot checked to assess.the gradation controls or both fine i and coarse aggregate. The records generally show conformance with specification requirements. The deviations noticed were primarily in 1978 and, in each case, were dispositioned by satisfactory retests of a new sample. The specification conformance improved in 1979 and continued good through 1983. i
- 17. Manatement Meeting -
At the conclusion of the inspection a meeting was held with WPPSS management and staff at WNP-3. Personnel in attendance are noted (*) in Paragraph 1 of this report. The inspector summarized the findings described within this report. The WPPSS representatives reminded the in,pector that the Readiness Review ! Program was a voluntary program by WPPSS and was intended to provide ! additional assurance of construction quality,'ove.r and above the confidence achieved from the existence of a quality assurance program during WNP-3 construction. The inspector acknowledged the WPPSS point and noted that WPPSS had requested NRC participation in the program and had presented the CAP as a basis for NRC acceptance of completed work. The inspector advised that his in process observations during this inspection indicated that the resulting g future CAP concrete report has the potential to be of insufficient depth to serve as the sole basis for NRC acceptance of completed work. The inspector noted that NRC may be able to conclude that completed concrete work was acceptable, however, such a conclusion would consider past NRC routine inspection efforts and findings and may also require significant additional NRC efforts to supplement the WPPSS findings, particularly in ; the area of analysis of the implications of prior problems. Subsequent to the management meeting, the Supply System mailed copies of additional records to the inspector, relating to the reinforcing steel clearances (paragraph 12.f) and grout damage (paragraph 13). Telephone conferences were conducted January 8, 12, 13, 1987 with participation of = the EBASCO quality assurance and engineering representatives. The inspector reaffirmed his view that regulatory requirements had not been satisfied with regard to these items. j 0}}