ML17276B379

Submits Revised Response to NRC 800121 Ltr Re Violations Noted in IE Insp Repts 50-397/79-10 & 50-397/80-08. Corrective Actions:Piping post-weld Heat Treatment Will Follow Bechtel Procedures

ML17276B379
Person / Time
Site:	Columbia
Issue date:	03/11/1982
From:	MATLOCK R G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	ENGELKEN R H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17276B378	List: ML17276B379
References
GO2-82-319, NUDOCS 8204070547
Download: ML17276B379 (16)

See also: IR 05000397/1979010

Text

Washington

Public Power Supply System P.O.Box 968 3000 George Washington

Way Richland, Washington

99352 (509)372-5000 Docket No.50-397 March ll, 1982 602-82-319

Mr.R.H.Engelken U.S.Nuclear Regulatory

Commission

Region V 1450 Maria Lane, Suite 260 Walnut Creek, California

94596 Subject: NUCLEAR PROJECT NO.2-CPPR-93 REVISED RESPONSES TO NRC NOTICE OF VIOLATIONS

79-10/01, 79-10/03, 80-08/09, AND 80-08/22 References:

a)602-80-120, dated June 11, 1980 b)602-80-209, dated September 19, 1980 Reference a)transmitted

the Supply System's response to Notice of Violation 79-10/01 and 79-10/03.Reference b)transmitted

the Supply System's response to 80-08/09 and 80-08/22.Subsequent

to the transmittal

of these replies, organizational

and procedure changes at WNP-2 have occurred which require submittal of revised responses for these four (4)violations.

The Supply System committed to provide these responses in NRC Inspection

Report 81-22.Attachments

1 through 3 fulfill that commitment

in part.The response to 80-08/22 is not included in this letter, but will be provided prior to March 19, 1982./LEAP<,W~Program Director, WNP-2 RTJ/kd Attachments:

(3)As stated cc: W.S.Chin, BPA-Site R.A.Feil, NRC Resident Inspector-Site A.Forrest, Burns and Roe-HAPO N.D.Lewis, NRC J.Plunkett, NRC R.E.Snaith, Burns and Roe, NY V.Stello, NRC RMSF-917Y j 8204070547

820331<PDR ADOCK 05000397.', 8 PDR

g(J r'C f;I

~(4)ATTACHMENT

1 Notice of Violation in letter from G.S.Spencer to N.0.Strand dated January 21, 1980 (GI2-80-17).

t Appendix A, Item A (79-10/01)

Notice of Violation:

10CFR50, Appendix B, Criterion IX, states,'n part, that"measures shall be established

to assure~that special processes, including...heat

treating..'.are

controlled

and accomplished

by...using

qualified procedures..." J Paragraph D.2.5.9 of the Supply System equality Assurance Program documented

in the PSAR, states, in part, that"measures shall be established...to

assure that special processes, including...heat

treating...are

accomplished

...using qualified...procedures..." Contrary to the above, on May 31, 1979, it was found that'the Piping Post Weld Heat Treating Procedure No.PWHT-1, Revision 4 (entitled"Post Weld Heat Treat Procedure No.1)was implemented

using a unique method of heat application

without the benefit of qualification.

The method employed electric resistance

heater blankets placed along each side of the weld (approximately

lf inches from the weld center line)rather than directly over the weld.This procedure had been used to heat treat safety related pipe welds including welds 6, 7, and 8 of Burns and Roe Isometric Drawing No.RFW-419-4.

This is an infraction.

Summary Due to Bechtel Power Corporation

assuming Contract 215 (WBG)system completion

work and associated

procedure changes, it is necessary to revise our response.Action to Correct Deficiency

Old Response: A one dimensional

transient analysis was performed*to

determine the maximum temperature

the feedwater piping reached, utilizing electrical

resistance

heater blankets specified in Post Weld Heat Treating Procedure No.PWHT-l, Revision 4.Because the transient analysis results disclosed that the maximum temperature

obtained anywhere on the pipe was below 1330 F, we concluded that the material adjacent to the weld and under the heating blanket, was not excessively

over heated and that post weld heat treatment performed did adequately

stress relieve the welds as desired.It is further noted that the analysis corroborates

the findings of Report No.IT-119, dated September 28, 1979;titled"Results of Hardness Testing and Metallurgical

Examination

on Feedwater Pipe Welds at Washington

Nuclear Project No.2." Y

Attachment

1 Page Two Action to Correct Deficiency (Continued)

New Response: It has been determined

that fifteen (15)Code Class 1 welds in the RFW system and five (5)Code Class 2 welds in the MS systems were post weld heat treated using procedure PWHT-l.A metallurgical

nondestructive

examination

was performed on weld 1Rl of piping isometric RFW 418-5.6.This weld was chosen as the potential worst case of ASME Code Class 1 welds in question.As a vertical piping run, the weld would have been subject to a chimney effect with respect to air flow and, although within Code allowable limits, this Class 1 weld achieved the highest temperature

on the strip chart recorder used in the PWHT process.Hicrostructure, grain size and hardness analyses were performed on the base material on the area directly under the initial heater blanket placement and also on a reference area approximately

six (6)feet from the weld area.The results of these examinations

provide justi-fication that adverse metallurgical

properties

have not been induced near the subject welds by the use of PWHT-1.A full report of this analysis has been generated and is available for review.Action to Prevent Recurrence

Old Response: New Response: None stated.WBG assumed direct responsibility

for all PWHT upon termination

of the PWHT subcontractor's

contract.WBG's procedure provided for in-line review and approval of PWHT procedures.

PWHT will now be accomplished

in accordance

with proven Bechtel procedures.

Date of Full Compliance

Old Response: New Response: None stated.WBG assumed responsibi

lity for PWHT effective September 12, 1979 in accordance

with approved procedures.

Bechtel assumed responsibility

for PWHT effective September 3, 1981, in accordance

with approved procedures.

a)4 0

ATTACHMENT

2 Notice of.Violation in letter from G.S.Spencer to N.0.Strand dated January 21, 1980 (GI2-80-17).

Apen'ix A, Item C (79 10/03), Notice of'Violation:

G01-80-55, D.L.Renberger to G.S.Spencer (3-5-80).10CFR50, Appendix B, Criterion XVII, states, in part, that"sufficient

records shall be maintained

to furnish evidence of activities

affecting.quality..." Contrary to the above, on May 31, 1979, it was found that sufficient

records shall be maintained

to furnish evidence.of satisfactory

heat treating of safety related pipe welding.For example, several heat treated record charts were ,illegible (e.g.welds 6, 7, and 8 of BRI Isometric Drawing'No.RFW-419-'4);

thermocouple

indications

were not recorded on some portions of the recorder charts (e.g.welds 1A and 2 of BRI Isometric Drawing RFW-419-5.7);

no oper'ators'ames

had been recorded on heat treating data records (e.g.welds 6, 7 and 8 of BRI Isometric Drawing RFW-419-4, welds lA, 2, and 3 of Isometric Drawing No.RFW-419-5.7);

different and conflicting

thermocouple

numbers had been recorded for the heat treatment of the same weld (e.g.the recorder charts and certification

sheets for weld 8 of BRI Isometric Drawing RFW-418-4, weld 1 of Isometric RFW-418-7.8, welds 6, 7, and 8 of Isometric RFW-418-4);

different (and conflicting)

dates of heat treatment had been listed on recorder charts and certification

sheets (e.g.welds 4, 6, 7, and 8 of BRI Isometric RFW-418-4, welds 1, 1A, 2 of Isometric RFW-418-5.6).

This is a deficiency.

Summary E Due to Bechtel Power Corporation

assuming Contract 215 (WBG)system completion

work and associated

procedure changes, it is necessary to revise our response.Action to Correct Deficiency

Old Response: WBG has initiated a program to review all completed PWHT charts and records for the PWHT conducted by Seattle Industrial...This

review activity is overviewed

by a ()uality Engineer who eval,uates

the findings.Inspection

Reports (IR's)are initiated as necessary to obtain resolution

of the discrepancies

found.New Response: WBG has reviewed all completed post weld heat treat (PWHT)charts and records for the PWHT conducted by Seattle Industrial.

The thoroughness

and adequacy of thi s review was documented

in WBG Corrective

Action Report gl53 and subsequent

status reports.Inspection

Reports (IR's)and Nonconconformance

Reports (NCR's)were initi ated to obtai n resolution

of discrepancies

found.

Attachment

2 Page Two Action to Correct Deficiency

New Response: (Continued)

The NOR's (53)documented

PWHT discrepancies

such as: o Temperature

above or below the required range.~Temperature

rise rate too high o Inadequate

number or location of thermocouples

o Inadequate

soak time o Missing or incomplete

records o Record anomalies Disposition:oF

these di screpancies

on the NCR's include:~Re-PWHT o Reirispection, including UT and RT o Hardness testi ng o Rejection, redesign, and refabrication'ction

to Prevent Recurrence

Old Response: New Response: As noted in B above, WBG has assumed direct responsibility

for the PWN operation and has initiated a program to assure compliance

to the revised PWHT procedure.

WBG assumed direct responsibility

for all PWHT upon'ermination

of'the PWHT subcontractor's

contract;WBG's procedures

provided for in-line ()A review of the completed PWHT records.PWHT wi 11 now be accomplished

in accord with Bechtel procedures.

Date of Full Com liance Old Response: The review of all records initiated by Seattle Industrial

and the initiation

of IR's for discrepant

conditions

is estimated to be complete by April 1, 1980.New Response: Review of records and documentation

of discrepancies

has been completed.

All NCR's have been prepared and dispositioned.

All NCR's.have been closed (required action done and verified)except for four (4), which require PWHT to be re-done.This re-PWHT will be performed by Bechtel as dictated by.system completion

and turnover activities.

ATTACHMENT

3 Notice.of Violation in letter from R.H.Engelken to R.L.,Ferguson, dated August 15, 1980.Appendix A, Item D.3 (80-08/09)

Notice.of Violation:

WBG ()uality Assurance Manual, Section 10 paragraph 10.3.I states, in part, that"all welling incl'uding

tack welding is performed by welders qualified as required by Section III and Section IX of the ASME Code." ASME Section III, paragraphs

NX-4321(b)

and NX-4321.2 reqUire the welders of temporary attachments

and tack welds to be qualified and that the material used for temporary attach-ments be compatible

for welding to the component material and be certified.

WBG Work Procedure No.42, paragraph 20 requires, with respect to"Welder Record," a record of welder's name(s), filler metal used (includes heat and lot':numbers as.applicable)

and the date(s)that welding was performed." Contrary to the above requirements, the weld record packages did not contain identification

of welders or filler metals used for tack welds and temporary attachments

made on pipe spools LPC-756-5.6, LPCS-756-19.21, and LPCS-2271-1.

This is an infraction.

Summary Due to Bechtel Power Corporation

assuming Contract 215 (WBG)system completion

work and associated

procedure changes, it is necessary to revise our response.Actions to'Correct

Deficiency

Old Response: The date and locations of all temporary attachments, welder and weld filler metal identification

are recorded on Form NF-286.A review of all work packages requiring traceabi lity will be conducted to determine when the NF-286 form is required.Copies of the required NF-286 forms will be incorporated

into the work packages.IR's will be issued when NF-286 forms are required but not located.Inspection

reports have been written on the weld record packages for pipe spools LPCS-756-5.6, LPCS-756-19.21, and LPCS-2271-1.

New Response: Same as above.Action to Prevent Recurrence

Old Response: Work Procedure No.42 has been revised and now provides for recording the welder identification, weld process, and identification

of the filler material for temporary attachments

and tack welds on the work package>veld=material.

Attachment

3 Page Two Action to Prevent Recurrence (Continued)

New Response: Work Procedure 42 has been revised and is now.incorpor-

ated into GWS-l,.Revision 3 (General Welding Standard, Repair Welding and NDE to Structural

Steel), and GWS-2, Revision 3 (General Welding Standard for Welding, Repair Welding, and NDE requirements

to Piping, Components

and, Supports).

These standards clearly provide for the recording-of

all pertinent information

for temporary attachment

welding in Sections 4.2.8 and 4.2.2 respectively.

WBG will perform the review of documentation

for the hardware they installed and identify any NDE reports not ,traceable

to a specific welding activity.Bechtel will'alkdown the'appropriate

hardware to determine if there is a related blended or rough area that is indicative

of removal of a temporary attachment.

Those cases where the document review, together with the hardware walkdown, indicates that a temporary attachment

was made without proper documentation

will be documented

on a NCR.Date of Full Compliance

Old Response: January 1, 1981 New Response: February 19, 1982

r r v I

Date ROUTING AND TRANSMITTAL

SLIP TO: (Name, office symbol, room number, building, Agency/Post)

Initials Date r~tr-+Ctg('v 4.5.ctlon pproval Requested irculate omment Coordination

File For Clearance For Correction

For Your Information

Investigate

Justify Note and Return Per Conversation

Prepare Reply See Me'ignature REMARKS Attached is.the original copy of a"Thank Youn letter sent to you and Washington

Public Power, P.0.Box 1223, Elma, WA 98/41.*This corrected-copy has the right Dock'et Number, Address, and Attention line.DO NOT use this form as a RECORD of approvals, concurrences, disposals, clearances, and similar actions FROM: (Name, org.symbol, Agency/Post)

8~oom No.-Bldg.Phon No.s->EIH-5 2 OPBONAL FORM 41 (Rev.7-tr6)Preecrlbed

by GSA*U.s.oovernment

Prlntlne ottleer t97$2$1.tee/$FPMR (41 CFlg 101-lle206

I

JAN 15 1982 Docket No.50-397 IP@~Z[@PPPgj

Washington

Public Power Supply System P.0.Box 968 Richland, Washington

99352 Attention:

t1r.R.G.Hatlock Program Director, WNP-2 Project Gentlemen:

(RECQQ'Pg 9 Jll>28 19gp~-12 V NQHg gggg~@TIDC Subject: NRC Inspection

at Washington

Nuclear Project No.2 (WNP-2)This refers to the inspection

conducted by Nr.J.0.Elin of this office.on November 2-5 and November 16-20, 1981 of activities

authorized

by NRC No.CPPR-93, and to the discussion

of his findings held by Nr.Elin with yourself and other members of your staff at the conclusion

of the inspection.

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 observations

by the inspector.

No=i.tems of noncompliance

with NRC requirements

were identified

within the scope'of--this inspection.

In accordance

with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application

to withhold information

contained therein within thirty days of the date of this letter.f Such application

must be consistent

with the requirements

of 2.790 (b)(1).lEOt OFFICE/SURNAME/DATE P RV/jk.EL IN//g d2"~~~~~~~....DS 1//3/82..FAULKENB ERR/1/g./82 ,'NRC FORM,318<10/80)

NRCM 0240'FFICIAL

R ECOR D'OPY+USGF0: 1980-829 824 j

v 4 J I 4 H lt E

0 JAN 15'58K Should you have any questions concerning

this inspection, we will.be glad to discuss them with you.Sincerely, Enclosure:

IE Inspection

Report No.50-397/91-22

B.H.Faulkenberry, Chief Reactor Construction

Projects Branch cc w/o enclosure:

R.B.Glasscock, guality Assurance Director ll.C.Bibb, Project Manager, MNP-2 Project G.C.Sorensen, MPPSS bcc: DMB/Document

Control Desk (RIDS)Distributed

by RV: State of llA (Lewis)Resident Inspector (8)Engelken (ltr)

~~E~I t I" N t II i~~(l H t I&l A I Sr I'1