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U. S. NUCLEAR REGULATORY COMMISSION.

OFFICE OF INSPECTION AND ENFORCEMENT

REGION V

Report No. 50-508/82-01

Docket No. 50-508 (C0N) License No.~CPPR-154 Safeguards Group

Licensee: Washington Public Power Supply System

P. O. Box 1223

Elma, Washington 98541

Facility Name: WNP-3

Inspection at: WNP-3 Site (Satson)

Inspection conducted: January 11-15, 1982

Inspectors: //d"./ /J/ 3[24/8 2D' P. Hais~t,feactor Inspector / D6te Signed

sGL D6%4 3kK8cA.J.D'Ang610,'RegtorInspector ' Dat6 Signed

Approved by: ( I MR. T. Dodos, Chief, Reactor Projects Section 2 /Date/ Signed

Reactor Construction Projects Branch

Sumary:

Inspection during the period of January 11-15, 1982 (Recort No. 50-508/82-01)

Areas Inspected: Routine, unannounced inspection by regional-based inspectorsof construction activities including review of procedures, observation of work, andreview of records for safety related pipe erection and welding and structuralsteel erection and welding inside the containment building; followup on a

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10 CFR 50.55e construction deficiency; and examination of licensee action onprevious items of noncompliance and inspector-followup items.

The inspection involved 64 inspection hours onsite and 13 inspector-hoursin-office by two NRC inspectors.

-Results: No items of noncompliance or deviations were identified.

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8204130328 820325PDR ADOCK 05000508G PDR

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DETAILS

1. Persons Contacted

The inspector interviewed various engineering, management,.

inspection and construction personnel of the organizations listedbelow. Key personnel, including those who attended the exitinterview are specifically identified below:

Washington Public Power Supoly System (WPPSS)a.

*N. C. Kaufman, Deputy Project Manager*J. A. Puzauskas, Quality Assurance Engineering Supervisor

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*C. E. Love, Construction Manager*0. E. Trapp, Project Quality Assurance Manager*E. L. Stephens, Quality Assurance Engineer:

b. Ebasco Services, Inc. (Ebasco)

*A. M. Cutrona, Duality Assurance Manager*J. P. Sluka,. Project Engineering _ Manager

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*L. A!. Bast, Ouality Assurance Engineering Supervisor'

D. L. Vance, Project Quality Engineer*R. G. Peck, Project Quality Engineer.M. Harris, Project. Quality EngineerK. Drinkard, Project Quality EngineerG. Scarfo, Support Design Group SupervisorP. Dimaculangan, Design EngineerG. Bedi, Design Engineer

c. J. A. Jones ' Construction Company (JAJ)

D. Cordaro, Quality Verification Supervisor

d. Peter Kiewit Sons Co. (PKS)(

J. Rhoades, Small Bore Piping Supervisor!

P. Smith, Quality Engineering Supervisor

* Denotes those attending the exit interview on January 15, 1982.In addition, Mr. W. G. Albert. Senior Resident Inspector attendedthe exit interview.

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I 2. Licensee Action on Previously Identified Enforcement Items

a. (Closed) Noncompliance (50-508/80-12/01) Wallace/ Superior Controlof Nonconforming Conditions

IThe licensee's actions in response to the noncompliance wereexamined in IE Inspection Report No. 50-508/81-12. At thattime the licensee had completed all commitments specified

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in WPPSS letter nos. G03-80-3239, G03-81-885 and G03-81-1010except for review of all Wallace/ Superior nonconformance reportsprovided to the licensee by Wallace/ Superior and review of othercontractor's deficiency control systems for problems similar tothose experienced by Wallace/ Superior.

During the present inspection the licensee's documentation forreview of Wallace/ Superior NCR's was examined. Five Wallace/Superior NCR's were also sampled by the inspector for proper dispositionby Wallace/ Superior. The licensee also completed the " mini audit"of all site contractor's deficiency control systems. Auditfindings are currently being reviewed by Ebasco for compliancewith specifications. This item is closed.

3. Licensee Action on Previous Followup Items

a. (Closed) Followup Item (50-508/509/80-15/02) - Policy forDocumenting and Voiding of Inspection Reports

The licensee had committed to review the policies of sitecontractors with regard to the voiding of quality assurancedocuments.

The inspector verified that a new Ebasco quality assurancespecification No. 860-W,' Revision 3 now requires that contractorsestablish a system for controlling nonconformance report formsand a process for voiding nonconformance reports or inspectionrecords which may indicate nonconforming conditions. Requirementsinclude written justification, review by . initiator and signofffor voiding documents. Ebasco personnel stated that theserequirements have been mandated on all safety related contractors

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except contract No. 224 and that contractors are revising theirimplementing procedures and submitting them for approval. The224 contractor has agreed to conform his implementing proceduresto these requirements. Based on these actions this item isconsidered closed.

b. (Closed) Followup Item (50-508/509/81-10/03) - Employee'sFreedom to Express Concerns About Ouality Issues

The inspector had expressed concern regarding a memorandumissued by the HVAC contractor (Wallace-Superior) requiringquality concerns to be brought to contractor management attentionbefore taking them to individuals in outside organizations,including the NRC. The basis for the inspector's concern isthe possibility that employees may be fearful of approachingtheir management with a concern.

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_ The licensee forwarded a written " Clarification of Policy"statement issued by the contractor during the week of November 16,1981 which addresses the inspector's concerns and providesemployees the requisite degree of freedom to report qualityconcerns to outside organizations. Accordingly the licensee doesnot now plan to address this item formally to NRC Headquarters.-This item is considered closed.

- c. (Closed) Followup Item (50-508/509/81-08/25) Use of CuringCompounds

The inspector had questioned how inspectors verified thatcuring compounds are applied and how the coating contractordetennined which curing compound has been applied so thatproper removal techniques are used prior to application ofsafety related coatings.

The inspector verified that quality verification inspectorsare required, by procedure, to witness curing compound application.The inspector also verified that the coating contractor's workplan requires identification and removal of incompatible curingcompounds. Surface preparation and removal of incompatiblecuring compounds is done by sandblasting, which will remove the epoxy-based curing compounds applied by J. A. Jones. Further, the coatingcontractor's routine practice is to remove all water soluble andepoxy-based curing compounds applied by J. A. Jones by sandblasting.Based on the above, this item is considered closed.

4. Licensee Action on 10 CFR 50.55(e) Construction Deficiencies PipeHanger Stiff Clamps

a. Background -

The licensee reported a potential 50.55(e) construction deficiencyinvolving the ITT-Grinnell Figure 215 Stiff Clamps on June 11, 1981.An interim report was received on July 13, 1981 describing the potential.

problems with the stiff clamps which included bending of the tie rods,torque relaxation, broken straps, and strap edge indications. .Theinterim report also described the approach to the resolution of theproblems. A final report was received on December 21, 1981 whichdescribed the deficiencies, an analysis of the safety implications,and corrective actions taken. Following the licensee's submittal ofan interim report the NRC received unsolicited comments on thestiff clamp design from an interested consulting engineer. Certainof these comments were considered to be particularly relevant andwere addressed to the licensee for resolution. The licensee'sresponse to these comments were included in the final report.Regional inspection efforts on this 50.55(e) construction deficiencyincluded a detailed review of licensee's final report focused on the

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materials and metallurgy involved, pipe support design andpipe wall stress, and examination of the defective clamps andfailure mechanism. The results of this inspection are presentedbelow. Unresolved issues not addressed in this report includethe acceptability of rivets in ASME Section III, NF components(Unresolved Item 50-508/509/81-02/09); clarification of theactual materials, design method, and change controls used byGrinnell (Unresolved Item 50-508/509/81-04/01); and clarificationof the effects on the rivets changing the heat treating sequence(Unresolved Item 50-508/81-04/02).

b. Design Characteristics

The licensee's technical specification for pipe supportsrequires that clamps used as non-integral attachments topiping in a snubber / strut assembly shall have, as a minimum, aspring rate greater than five times the spring rate of thesnubbing device. In response to this requirement ITT-Grinnelldesigned the Figure 215 Stiff Clamp. The stiff clamp consistsof two ferritic stainless steel bands with riveted loops ateach end. One end of the straps is attached by pins to a yokeassembly which bears against the pipe wall. The other end ofthe straps is attached to tie rod assemblies which are torquedto tighten the straps to obtain the required stiffness.

The initially identified problems of torque relaxation andbending of the tie rods were corrected by modifying the design.Requalification testing on the aew design was performed toensure that the changes would act affect the overall designintegrity and that the required stiffness characteristicswould be met. The requalification test results were examinedby the inspector and found to be acceptable.

c. Resolutiion of Identified Deficiencies

The problem of_ strap failures'during shop and site testing wasattributed to the original, design. . Load. qualification testsperformed on the modified design have resulted in no strap

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failures at the required design load. The design modificationshave resulted in lower torque values and a correspondingincrease in safety margin between~the required installationtorque and the failure torque.

Edge indications in line with the strap holes have been determinedto result from cold working of rivet holes. Certain of thestrap rivet holes were produced by the cold working processesof punching followed by a " coined" countersink. Coining isaccomplished by cold impact which moves the material from thecountersink area and displaces it outwardly. The resultingbulge of material at the edge of the straps and subsequent

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edge conditioning was judged to be the source of the edgeindications. Ebasco representatives stated that the edgeindications have no' apparent effect on the overall strength orintegrity of the straps and that full rated load was attainedon tests of four (4) straps. with edge indications. Strapswith visible edge indications, however, will be rejected.

d. Evaluation of Licensee Submittal

The inspectors reviewed data on the stiff clamp materialsagainst the ASME Code Subsection NF requirements. Strapmaterial was purchased to ASTM-A693 GR.630 in the annealedcondition. ITT-Grinnell performed age hardening operationsand recertified the material to SA-564 GR.630 in the H1075condition. ITT-Grinnell has taken the position that as amanufacturer, .they can begin with ASME material and recertifythe material as a result of the manufacturing processes orprocedures as_long as the chemical and mechanical propertiesreflect ASME material properties following manufacturing.Ebasco has requested ITT-Grinnell to furnish a code case orinterpretation to support this position. This code case will.'

be examined with Unresolved Item 50-508/509/81-04/01.,

Thisinspectornotedthattheheattreatmentstrigchartsindicate age hardening at slightly les.s than 1050 F whereagothe H1075 condition requires heat treatment at 1075 F 115 Ffor 4 hours. The licensee was requested to justify this deviationfrom specification requirements. This item will be examined withUnresolved Item 50-508/509/81-04/01.

The rivet material specified on ITT-Grinnell design drawingswas SA 453 Grade 660. The material received had been annealedand heat treated in accordance with National Aerospace Specifi-cation NAS-1199. Neither the licensee nor Ebasco could explainITT-Grinnell's deviation from the design drawing. The NASmaterial supplied differed from the SA .453 GR660 material in thatit was received in the annealed condition and then heat treatedin accordance with NAS-1199 requirements. Corrective action forthese deviations from ASME Code material requirements is tosubmit code cases describing the treatments performed. These

! code areas will be examined with Unresolved Item 50-508/509/81-04/01.

From a pipe support view point, the intent of the stiff clamp isto provide a pipe clamp which will have a low deflection under load.ITT-Grinnell Load Capacity Data Sheets for the Figure 215 stiffclamp show the following maximum faulted load capacity and springrate for a given frame size:

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Frame Size Maximum Load (lbs.) Sprino Rate(lbs./in)

51 11520. 3.25 X 102 11520. 3.25 X 10

53 11520. 3.25Xlg4 26700. 1.0 X 10

65 26700. 1.0 X 1066 26700. 1.0 X 10

The high sprin'g rate for the stiff clamp is achieved by preloading thestiff clamp straps .to a stress level higher than the stress that willdevelop in the straps due to any pipe reaction load. Therefore, no pipelift-off from the stiff clamp frame will occur. It is apparent

that any significant amount of relaxation in the straps, strappins, trunnions, tie rods or frame will reduce the load at whichpipe lift-off will occur and therefore lower the spring rate.

The necessary preload force for the stiff clamp design stiffness willapply an intermediate radial load upon the pipe wall. An additionalamount of radial load will be applied to the pipe wall when a stiffclamp is used to support stainless steel pipe, due to the differencein the coefficient of thermal expansion of the strap material usedin the stiff clamp and the coefficient of thermal expansion ofstainless steel. The coefficient of thermal expansion for the strap

material,whichisaferriticstaingessstegl,isapproximatelyequalto that of carbon steel (7.33 X 10- in/in/F)6andisgomewhatlower than that of stainless steel (9.87 X 10 in/in/ F). Thisdifference in coefficients will yield an additional load on thepipe wall due to more rapid growth of stainless steel pipe thanthe stiff clamp straps as the piping system heats up from ambienttemperature. The thermal growth effect will also produce anintermediate radial load in addition to the preload force.

These loads, however, do not produce uniform membrane stress withinthe pipe wall along the circumference due to changes in the stiffclamp-to-pipe contact area. The stiff clamp straps are approximatelyone and one half (1 1/2") inches wide and conform to the pipesurface for approximately two thirds (2/3) the pipe circumference.The remaining surface is contacted by the stiff clamp frame whichis approximately one quarter (1/4") inch wide for frame sizes 1, 2and 3 and one half (1/2") inch wide for frame sizes 4, 5 and 6.-

So two thirds (2/3) the circumference of the pipe wall is contactedby a strap which is wide and conforms to the pipe wall. Theremaining one third (1/3) of the pipe wall circumference iscontacted by a steel plate one quarter (1/4") or.one half (1/2")inch wide which does not mold to the pipe wall surface and is notmachined to match the pipe wall surface and may achieve only "line"contact with the pipe wall. Also, one frame size accommodates severaldifferent pipe diameters. Therefore, the circumference of the pipewall in. contact with the frame changes as a function of pipe diameter.

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From the above stated observations, a calculation was made todetermine the membrane stress within the pipe wall for the localarea in contact with the stiff clamp frame. The assumed load wasdue to thermal growth plus preload. A resultant force of 26700lbs. was calculated acting on the pipe wall in contact with theframe. Assumptions included a frame size #2 supporting an eight(8") inch stainless steel (TP304) schedule 40 pipe. Equations formembrane stress were taken from tables 30 and 31 of Formulas forStress and Strain by Roack and Young. Results, from the abovestated problem, yielded membrane stress approaching twice the valueof the design stress intensity value, which appears toleave little margin for any additional stresses in the pipe due toother piping reaction loads.

The above calculation is understood to contain several assumptionsand simplified methods which yield conservative results.Assumptions are: line contact with frame, no radial deformation

and asymmetric loading.

ITT-Grinnell is in the process of performing membrane stresscalculations, however, the inspector's concern is that even witha rigorous analysis such as an ANSYS approach, membrane stresscaused by the stiff clamp frame / pipe wall interaction will leavelittle, if any margin for additional stresses in the piping element.Any additional stresses would appear to.make it difficult to remainwithin code allowable limits.

e. Conclusions

The stiff clamp redesign, in conjunction with successful resolutionof ASME code acceptability issues and resolution of the membranestress issue may render the Figure 215 stiff clamp an acceptablecomponent. The inspectors remain concerned over the ability ofthe stiff clamp to function effectively for the 40 year design life

' of the plant. These concerns stem from (1) the initial designdifficulties which indicate inadequacies in the original designdevelopment and testing program; (2) deviations from ASME Codematerial specifications without any apparent recognition byITT-Grinnell of the' need to request code cases; (3) the high straptension values required to achieve the design stiffness factor;(4) the possibility that other mechanisms not considered, such ascreep or stress corrosion, could effect the continued operabilityof the straps; and (5) the need for finite element analysis techniquesto evaluate the membrane stress levels induced by the strap and yokeassemblies. The regional staff has requested additional review of

This 50.55(e)y the Office of Nuclear Reactor Regulation (NRR).this design b

item will remain open pending the additional reviewand resolution of the regional concerns expressed elsewhere in thisparagraph.

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5. Containment (Steel Structures and Suoports) - Contract 265

a. Review of Ouality Assurance Implementing Procedures

The inspector reviewed the following work procedures associatedwith structural steel erection and installation of the upperstructures for the steam generator keys and snubbers. The4

procedures were reviewed against the requirements of the PSAR,the AISC manual of steel construction, the AWS structural weldingcode, and appropriate ANSI standards.

Procedure No. Title

WE-SITP-102, Rev. 3 Site inspection and Test Procedure forWelding Inspection

WE-SP-107, Rev. 4 Special Process Procedure for Stud Welding

WE-WP-18, Rev. 2 Construction Work Procedure for Lift andInstallation of D-Ring Upper Stream GeneratorSupports'

WE-WP-ll, Rev. 3 Construction Work Procedure for Weld FillerMetal Control

WE-WP-4, Rev. 3 Handling, Storage and Erecting Structural Steel

The inspector noted that procedure No. WE-WP-4, Revision 3 did notcontain minimum bolt tension values for SA-193 Grade B7 bolts whichare being used on field splice connections on the steam generatorupper support steel. The contractor immediately issued an intermprocedure change notice to include the tension values being used.

No items of. noncompliance or deviations were identified.,

b. Observation of Work and Work Activities'

The inspector observed the following work activities on the*

south upper' structure for the steam generator keys and snubbers:turn-of-the-nut tightenin~g of SA-193. field splice connections,stud weld process qualification, replacement of studs removed to

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enable installation of the structure, bend testing of studs, and,

random examination of the shop fabricated portion of thestructure against shop' drawings for member size and location, weld

; size, shape.and location, stud weld quality and location.

No items of noncompliance or deviations were identified.

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The inspector observed modification of reactor building columnbase and cap plates in accordance with nonconformance report

: No. 265-3352 to allow columns to fit mislocated anchor bolts.Columns are being modified by either (1) slotting existing holesand adding a new cap plate or (2) slotting existing holes andapplying weld buildup opposite the direction of slotting. Theinspector examined these modifications for weld sizes,configurations, and edge distances specified in the nonconformancereport and examined the process control sheets for adequate controland quality verification hold points.

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No items of noncompliance or deviations were identified.

6. Management Meeting

The inspector met with the licensee and management personnel denotedin paragraph 1 at tne conclusion of the inspection on January 15, 1982.The inspector discussed the scope and findings of the inspection. Thefindings were acknowledged by the licensee.

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