GO2-80-209, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/80-08.Corrective Actions:Memo Issued to Clearly Establish & Reaffirm Qa/Qc Independence from Const

Responds to NRC Re Violations Noted in IE Insp Rept 50-397/80-08.Corrective Actions:Memo Issued to Clearly Establish & Reaffirm Qa/Qc Independence from Const

ML20062J561
Person / Time
Site:	Columbia
Issue date:	09/19/1980
From:	Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17275A660	List: GO2-80-209, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/80-08.Corrective Actions:Memo Issued to Clearly Establish & Reaffirm Qa/Qc Independence from Const
References
GO2-80-209, NUDOCS 8010310050
Download: ML20062J561 (15)

Text

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p o. no. ees sooo cio was orose way seicata o, wasnimoto ses's2 es w 3[% NiInb65 S N 00 tp of September 19, 1980  %., y, J 4, G02-80-209 T7"._q"',. \ 'I Ftr. R.II. Engelken, Director Office of Inspection and Enforcement i Nuclear Regulatory Commission Region V j Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, CA 94596 i

Subject:

WPPSS NUCLEAR PROJECT NO. 2 I

• DOCKET NO. 50-397, CPPR-93 NRC INSPECTION - June 3 - July 25, 1980 r

REPORT NO. 50-397/80-08

Reference:

Letter R.l!. Engelken to R.L. Ferguson, dated August 15, 1980

Dear Mr. Engelken:

i 1 Washington Public Power Supply System hereby replies to the Notice of Vio- ] lation which was transmitted to us as Appendix A to your letter dated August i 15, 1980. The reply pursuant to 10CFR paragraph 2.201 consists of this let-ter and Appendix A. The scope of the reply to the Notice of Violation in- ] cludes the matters relating to that notico discussed both in your transmittal

;               letter and in the text of Appendix A itself.                                                                                        I In Appendix A, we quote the items of noncompliance from Appendix A of your August 15, 1980 letter, address the corrective actions which have already been or will be taken to correct the noncompliance, identify actions which aircady have been or will be taken to avoid further items of noncompliance and the dates when full compliance will be achieved.

If you have any questions or you desire further information, please contact me, j Very truly yours, k $ D.L. Renberger Assistant Director, Generatton and Technology DLR/JPT/nsm

Attachment:

as stated cc: JM Blas - BTR, NY - w/1 IIR Cantor - BfR, NY - w/1 i JR Lewis - BPA - w/1 V. Stello - Office of Inspection f JJ Verderber - BTR NY - w/1 Enforcement, WDC - w/1 8~010810 @ g.Q'

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f , APP 20]IX A Washington Public Power Supply System P. O. Box 963 Richland, Washington 99352 Construction Permit No. CPPR-93

        .                                   NOTICE OF '.'IOLATI0d Based on toe results of an JRC investigation conducted between June I through Ju ly 25, 1930, it appears that certain of your activities were not conducted in full compliance tith conditions of your intC Facility License ilo. CPPR-93 as indicated beioa.

Tne flRC investigatian revealed signirican; deficiencies in your quality assurance progra:a, in that work perforaea by the contractor, Wright, Schuchart, Haroar, Boecon, 3cvee o Crai1, GERI (WdG), did not confonn to the criteria of 10 CFR 50, Appendix 3, as described in Appendix 0 of your PSAR. Specifically, priur to June 1930, the ite.as listed below had not been identified or corrected by the project quality assurance organization. L #

A. 10 CFR 50, ippendix B, Criterion I, and PSAR, Appendix D, paragraph 0.2.5.1 states, in part, that "The persons and organization performing quality assurance functions shall have suf ficient autnority and organizational freedom to identify quality proolems; to initiate, recommend, or provide solutions; to verify implementation of solutions. Such persons and organizations performing quality assurance functions shall report to a management level sucn that this required authority and organizational freedom including sufficient independence from cost and scnedule when opposed w safety considerations,.are provided." Contrary to the above requirements, on ilovember 15, 1979, your site contractor (W3G) responsible for safety related mechanical construction and related quality assurance functions, established the authority of the Swing Shif t Construction General Superintendent to order the tennination of swing shift QA/QC personnel. Memorandums llos. LGB-229 and PWS-063 from the contractor's QC tlanager and QA Manager documented this authority of the Swing Shift Construction General Suoerintendent. This is an infraction. ACTION TO CORRECT JEFICIEilCY On July 23, 1930, Wright, Scnochart, Haroor/80 econ / General Energy Resources, Inc., (WdG) QA Manager rescinced Interoffice Memo ilo. PWS-063, dated December S,1979 and interof fice Memo No. LGB-229, dated flovemoer 15, 1979, by issuing Interoffice Memo ilo. TBP-009, dated Septenber 9, 1980. This memo clearly establishes and reaf finns QA/QC independence from construction. ACTIONS TO PREVEuf RECUdREriCE The QA/QC managers responsible for issuing the rescinded Interof fice Memos have oeen replaced. A letter will be sent to all site contractors stating the intent of 10 CFR 50 with regard to QA/QC independence from cost and schedules. DATE OF FULL COMPLIANCE 10/1/80 2

d. 10 CFR 50, appendix d, Criterion V, states that " activities affecting quality shall oe prescribed of documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures or drawings shall include aopropriate quantitative or qualitative acceptance criteria for detennining that important activi ti30 have been satisfactorily accomplisned."

Paragraph 0.2.5.5 of the QA Program as delineated in the PSAR states in part, that " Activities af fecting quality...shall ne accomplished in accordance with these instructions, procedures, or drawings..."

1. The contractor's " Field Quality Assurance Manual", Revision 10 for WPPSS Contract No. 2808-215, in paragraph 17.2.3 states, "The completed document package shall be delivered to the Project Quality Assurance Manager or his designee for review and acceptance. He will indicate his acceptance by signing the work package".

Contrary to the above, as of dune 9,1980, the document package for loa pressure core spray pump LPCS-P-2 which had been reviewed and accepted by the Quality Assurance Manager's designee on December 10, 1979, was incomo iete. Quality records in tne package pertaining to equipment bolting and alignment (forms NF-159) are dated Decenber 11

 .             and 13, 1979.

This is a deficiency. ACTIOJS TO C0ddEC T d2FICIENCY This condition occurred as a result of additional work being required subsequent to tne wor < package approval. The document package for LPCS-P-2 has been reviewed ajain, the deficiency corrected and approved. Inere are only eight equipment installation packages in the WdG QA vault that h1ve been reviewed and accepted. These eight packages will be reviewed again to assure that they do not have the same deficiency. ACTIONS TO PREVENT RECUMEdCE Work Procedure 30. 115 and Work Procedure 40. 86 will be revised to prevent completed work packages from being returned to the ficld af ter approval. This will be accomplished by requiring all rewors and ravision of packages to be done througn the usage of addendum work packages. Addendum packages will be reviewed and approved in the sa.iie cianner as the original package when completed. DATE OF FULL COMPLIANCE 12/1/30 3

9

2. WdG Quality Assurance Procedure, QAP-5, paragraph 1.1 states tnat the " procedure provides the responsibilities and methods for the l 1 control of nonconfonaing conditions found in... construction '

activities" and further prescribes in paragraph 3.1.2 that "Qnality Assurance, Quality Control and Qaality Engineering personnel shall initiate an inspection report (IR) upon discovery of an apparent discreaant condition." The W3G QCI-2 -(Non-destructive Testing Procedure for Magnetic Particle Inspection) required in paragraph 5.7 tnat nagnetizing current shall be used at a minimum of 90 and a maximum of 110 amps per inch of prod spacing for sections less than 3/4" thick. Contary to the above requirements, the inspector observed that two surveillance reports, performed by the WBG Level III examiner, each dated 9/12/79, identified tnat, during tne performance of magnetic particle examinations of material less than 3/4" thick, the amperage was not lowered following a decrease in prod spacing from 4.5" to 3" thereby increasina the amoerage from approximately 100 amps per inch to 150 .aus aer incn. Tne reoort identified this as a noncomoliance with specifications and no insoection report was written. This is a deficiency. ACTION TO CORRECT DEFICIENCY Inspection Report No. 6074 was wri tten to document the discrepancy. All previous surveillance reports will be reviewed to assure that inspection reports were generated as required. ACTION TO PREVEdT RECURRENCE WdG will review quality Assurance Proceouce do.15 to assure adequate 4 instructions are provided for the inspector. The Level III examiner will be retrained to tha requireinents of docu..lenting nonconfonaing conditions. DATE OF FULL COW LInaCE 12/1/80 4

3. Piping isometric drawings .;-290-11.20 and SW-297-8.17 identify that these spools are subject to the requirements of the ASME Boiler and Pressure Vesse.1 Code,1971 Edition, Section III, Class III and were identified as Quality Class I. The e< amination requirements and acceptance criteria for welds in ASME Section III, Class III piping, pumps and valves are specified in paragraph ND-5220.

Contrary to the above requirements, the governing acceptance standard identified in Northwest Industrial XRay Liquid Penetrant Examination Reports Nos. 230 and 244, dated July 31, 1975 and August 20, l'J75 respectively, was ASME Section VIII. The liquid penetrant examination reports indicated that the results of these examinations performed on pipe spools SW-290-ll.20 and SW-297-8.17 were evaluated to tna acceptance standards of ASME Section VIII. These standards are less stringent than those required by ASME Section III. This is a deficiency. ACTIONS TO CORRECT DEFICIENCY Inspection Report No. 6047 was written to document tne discrepancy. WBG will review all completed liquia penetrant reports and segregate tnose reports with the incorrect accepta: ice standara ano document any auditional discrepancies on Inspection Reports. Tnese discrepant liquid penetrant reports will be

 . reviewed against tne ASME Section III requirements ano appropriately dispositioned.

ACTIONS TO PREVENT RECURRENCE The acceptance criteria for liquid penetrant exaaiinations are delineated in QAP-16. These acceptance criteria conform to ASME Section III requirements, even tnough QAP-16 references ASE Section VIII in adaition to ASME Section III. QAP-16 will be reviseo to delete reference to ASME Section VIII. DATE OF FULL COMPLI AICE 12/1/80 5

4. WdG Quality Control ProceJure No. 24 (QCP-24), Attacnment 2 (dox in Clearance) requires that for systents under 2000 F and piping sizes from 2 1/2" to 12" the maximum allowed clearance between support and pipe, when summed on both sides, be 1/8". QCP-24, Attachment 6 (Stop Clearance) specifies that the sum of clearances between both pipe stop attach.nents and the support structure be a maximum of 1/8".

Contrary to the above requirements, the inspector observed the following: (a) The summed horizontal clearance between the 4" pipe and support was 3/16" for support No. EDR-362. The support was as-built by W3G Engineering and inspected and accepted by QC on March 22, 1979. (b) The summed horizontal clearance between the upper pipe stops and the support structure was 7/32" for support No. RCC-457. The n-built drawina hau been orecared oy WBG Engineering and tae support inscected ana accepted by QC on December 7, 1979. Inis is an infraction. ACTIONS TO CORRECT DEFICIENCY Inspection Reports have been issued for cotn Edd-362 and RCC-457. The entire "as-built" program is being revised and all previous "as-builts" will be reverified oy WBG for comp liance to tne new "as-built" precedure. Conditions which do not comply witii the "as-built" procedure requirements snall be documented on IR's and appropriately dispositionea. Final acceptaoility of the "as-built" aill be determined during tne A/E technical acceptance of the "as-built" hanger drawing and tne >yste.a stress review. ACTIONS TO PREVEdi RECURREWCE W3G is developing a new training prograa and will train all its employees to all applicable procedurec pdar to sending them out to tne field to perform any quality related work. DATE OF FULL COWLIAUCE 11/1/30 i 6 l l

5. WBG Project Directive rio. 75, paragraph 6.3.1 states that "CalcJlations required for minor re-design shall be limited to:

those cases involving any changes in the sizes of members, welds or configuration, whicn will result in increasing the stress in members of connections..." WdG Project Directive flo. 75, paragrash 7.1.3 also states, in part, "All moaifications...shall be noted on the support detail to reflect field revised conditions prior to performing the work and ir.itialed and dated by the Field Engineer or WBG Design Supervisor." Contrary to the above requirements: (a) Ine "as-built" drawing for support MSLC-21 modified the originally approved detail in such a way that the originally specified 1/4" fillet, all around, for attaching PC2 to PC4, was changed to a 1/4" fillet only on the outside of each PC2 flanga and a full slot weld attachina the web of PC2 to the flange of PC4. ine deletion of tue fillet weld on tne inside of tne flanges of PC2 would increase the stress in tne connection. Calculations had not been prepared to justify the comge ano the cnanged welding details were not initialed or dated. (c) Ine "as-ouilt" drawing for support RHR-326 was revised to specify a new weld joint without the necessary calculations to justify tne change. The weld attacning the Luorite assemoly to tne pioe was originally specified as a bevel-groove weld. On 4ay 15, 1930, tne welo symool was modified by WBG Engineering ta indicate a square outt (groove) weld since the weld

onfiauration diJ not conforai to a bevel-groove weld. The nisting veld is not a groove weld configuration, but is coniigured as a " cap" weid.

The "as-buii t" drawing had been prepared by WBG Field Engineering on May 3, 1930, and the support inspected and accepted oy QC on May 9,1980, with a note that the snubber was missing. Tne EQA audit identified tnat this weld was undersized and not welded to detail. The EQA finding was res0lved by the notation that the weld syinbol was changed and tne weld was "ok" on May 16, 1980. ilo calculations were perf]rmed justifying the adequacy of the resolution provided for the EQA finding. (c) ine weld details of the "as-built" drawings dated June 8, 1979 for support flo. RRC-3 were modified to conform to the "as-noilt" configuration on January 24, 1930 by a WBG engineer. This changed the welding detail from that approved by Burns & Roe in the original drawing on March 11, 1973. The changes involved the deletion of a' fillet weld and addition of a weld across the flange of an I-beam. Calculations and the designer'; approval were not provided to support the acceptibility of this design change. This is an infraction. 7 I

5. Continued ACTIO:lS TO CORRECT OEFICIENCY Inspection Reports have been issued for hangers MSLC-21, RHR-326 and RRC-3.

These hangers will be "as-built" again, technic ~lly a reviewed and design verification performed under the sane program wriich was described in the response to the previous infraction. ACTIO:15 TO PREVEilT RECURREilCE In the future, all design changes will be approved by the A/E prior to the changes being made. Tne W3G task force that is reviewing the hanger installation requirements and procedures is making changes to installation procedures to assure that installations are performed to specification requirements. DATE OF FULL COMPLIANCE 12/1/30 s t I E b i

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6. Contract specification 2803-215, Section 17A, paragraph 3.4 requires that weld filler material for welding P-8 material shall be " type E303 or type E316 or as specified in the approved weld procedure".

The WBG Welding Procedure Specification 45 ( ~or P-8 material welding) requires E303-16 filler metal. Contrary to the above, on October 11, 1979 and thereabout, WBG personnel welded eighteen P-8 to the P-8 material socket welds with the incorrect filler netal and uitn the incorrect welding procedure. Welds numnered MS-533-1-FW2 through MS-555-lFW2 were completed using E309-lo filler netal using welding procedure specification 16 (for P-8 to P-1 welding). These are welds of thernowells to nozzles on safety relief valve lines. This is an infraction. l i ACTIONS TO CORRECT DEFICIE'EY A Nonconfonaance Reaort (UCR-5404) was issued on these welds. Tne proposed disposition of this dCR was to "acceut-as-is". This disposition was accepted by the A/E. This deficiency was causeo by an incorrect weld callout by.the weld engineer. To assure that tnis was an isolated case, a sample of tne weld records prepared by cnis weld engineer will be reviewed for accuracy. Based ' on the results of tne review, appropriate corrective action will be implemented, if requ ired. ACTION TO PREVENT RECURREICE If there are additional errars discovered during the review of weld records, appropriate actions will be taken with regard to the responsiole weld engineer and his previous ..<ork. The QA Progra:ii deview, now under way, is reviewing NCR 's, Id 's, e tc., for potential trends. Corrective action will be taken, as necessary woen trends are iJentified. DATE OF FULL CONLIAiEE 11/1/30 i . 9

7. The W3G Work Procedure 110. WP34, Weld and Repair Procedure for ,

Structural Steel within the Reactor Drywell - Attachment Welding to Sacrificial Shield Wall, Paragraph 8.2 states, in part, "each weld shall be magnetic particle tested as a minimum...at 72 hours or more after conpletion and cooldown of tha last weld in the sequence..." Contrary to the above requirement, as of June 10, 1980, accepted welds 5-l and 6-1 attaching pipe support E0R-392 to the sacrificial shield wall had not been magnetic particle tested. The pertinent olocks on For.1 UF-63 for documenting tne required inspections had oeen marked "MR" (not required). Inis is an infraction.  ; ACTIONS TO CORRECT DEFICIENCY Work Procedure No. 84 is a comorehensive work orocedure which invokes attachments for specific tvoes of joos. For the weldino of EDR hangers , attachment 52 is required. The insoector selectea attacnnent 83, which is for : the most common situation encountered. This attachment does not require the 72 hour MT. An Inspection Report was written to cocument tnis deficiency. The 72 hour MT has now Deen perrormea and found acceptable. A sample of the hanger packages that were wor <ed to the requirements of Work Procedure No. 84

 . will be reviewed to cetermine if tnis proclem is of a generic nature.       Based on the sarnpie review results all of these packages will be reviewed.

Inspection Reports will be issued for all discrepencies found and corrected. ACTIO::S TO PREVENT RECUdREuCE Work Procedure Wo. d4 uill ce reviewed witn tne intent of simplifying and consolidating it's requirements, so that it will be clear woich attachment is to be used under all conJitions. All WG personnel performing work and/or inspections in accordance witn Work Procedure No. 84, will be trained to Work Procedure :10. 34 prior to going out in the field. DATE OF FULL COM?LIAI.CE , 12/1/80 I 10

C. 10 CFR 50, Appendix B, Criterion VI, and Appendix D, paragraph 0.3 of the PSAR state, in part, " Changes to documents shall be reviewed and approved by tne s tne organizations that perfonced Se original review and approval unless tne applicant designates another < ,onsible organization." With respect to the control of traceabilit' of certified materials tne WBG procedures QCP-24 (paragrapn 6.5), Project Directive No. 75 (paragrapn 7.3.1) and QCP-17 (paragraph 5.1) state that "When a part is cut from an originally identified piece, the identification shall be accurately transferred to the Cut pri3r to tna Cut". Tnese procedures were approved for f abrication by durns & Roe on the dates indicated: Project Directive No. 75 (Hanger Engineering Standard), Revision 4, on June 26, 1979; Quality Control Procedure No. 17 (Traceability Procedure), Revision 8, on April 4, 197); and Quality Control Procedure No. 24 (Hanger Inspection-Traceability Systems), Revision 8, on April 11, 1980. Contrary to the above reauirements, on January 18, 1980, the WBG QA Manager issued an interof fice memo (Ho. PWS-102) to all QA/QC personnel, without prior durns & Roe approval, wnich modified tne traceability car'<ing requirements of tne above proceaure in that the memo eliminated the reqairement to provice a traceaoility mark on tne material. This is an infraction. ACTIOHS TO C0ddECT dEFICIENC_Y_ Interof fice Me.no No. PWa-102, dated January 18, 1930 has been rescinded by Interoffice demo No. TP3-033, dated August 1, 1980. Work accepted under the direction of the rescinded memo will be identified and Inspection Reports will be issued if deficiencies are found. ACTIONS TO PREVEJT RICUddEdCE 1 An Interof fice Me..ia 30. TM -107, dated Septe.nuer 9, 1930 has been issued emphasizing the reqJirement that all changes to documents shall be reviewed and approved by tha same organizations as the original documents, and that memos shall not be used to alter procedures. -QCP-24, QCP-27, and Project Directive 7S have all been incorporated into WP-ll7. Work Procedure Ho. 117 is being rewritten to clearly establish the traceability requirements. A letter will be sent to all site contra. tors stating that changes to documents shall be reviewed and approved by the same organizations that perforoled the original review and approval. DATE OF FULL CUWLIANCE 12/1/80 11

D. 10 CFR av, Augendix B, Criterion XVII, states, in part, that " sufficient records shall be maintainea to furnish evidence of activities affecting gaality. The records snall include at least the following: operating logs and tne results of reviews, inspections, tests, audits, monitoring of wor < performance, and materials analyses... Records shall be identifiaale and retrievaale." The WPPSS implementing commitment for 10 CFR 50, Appendix 3, Criterion XVII, is descrioed in Appendix D, paragraph 0.3.4.17 of the PSAR wnich states the required records snall be identifiaole and retrievable. Contract specification 2808-215, Part 52A, Section 3.17, requires the contractor to implement a system of receipt control snich shall include a records clerk list designating the required quality assurance records structured to permit a current and accurate assessnent or tne status of quality assurance records during tne process of records receipt.

1. The Contractor's Field Quality Assurance Manual, paragraph 17.2 states, in part, that "...as documents are received they shall be check 2d for comoleteness and acceptability...a document Cnecklist shall oe preparea..."

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Contrary to tne acave: a) Un Jane 23, 1930, a document cnecKlist was not preparea nor was another metnoa estaolished for performance of an accurate and carrent assessment of tne status weld repair records for structural steel at elevation 524' of the reactor containment bailainq. document reviewers could not assess from the records wnatner or not they nad all of the weld records for repairs of steal snawn on drawings FS4-215 througn F54-217. b) do decemoer 2d, 1979, the contractor certified as complete, the acards package for structural steel at elevation 505' of tne reactor building, although neither a checklist or otner method had yet oeen estaalisnad for assessing the status of the recorus. Inis is a Jeficiency. ACTIONS TO CORREC T UEFICIENCY A cnecklist will be developed in oraar to establish.a complete listing of all records required for a completed work package. A checklist will also be developed that will list all documentation of each work package that was previously accepted. These checklists will be checked against each other and all discrepancies will be documented on inspection reports. ACTIONS TO PREVCNT RECddRENCE All new war < aill have work packages developed using a checklist of required  ; items. The tas< force that is developing these checklists is also i establishing guidelines unich will be used during the review of work packages. DAfE OF FULL CdNPLIANCE 1/1/30 - l 12 l l 1

     .           2. Contract Specification 2303-215, Section 52A, paragraph 3.8 requires that " Objective evidence shall be available which substantiates the I

approval of a vendor as an acceptable source of equipment, material I or service". The Contractor's Quality Assurance Manual, Section II requires in paragraph 3.2.1, "All purchases are made from either A , or d vendors on the Approved Vendor's . List" and in paragraph 3.2.4, '

                      "A file shall oe maintainad on eacn vendor, including the original basis for acceptance, and oeriodic recorts of service experience".

Contrary to the above requirements, on Septemoer 11, 1973, the Bovee and Crail/GERI QA Department issued a letter to Puget Sound Company identifying that the vendor was " supplying ASME material to us in violation of the ASME Section III, paragraph NA 3732". No perica report of the service was in tne vendor file, and no other data was [ available to identify the nature of the violations, their evaluation, and disposition of the material. This is a deficicacy. ACTIONS TO CORRECT DEFICIENCY , The survey report initiating tne action against Puget Sound Company cannot be located by WJG. W3G nas initiated Corrective action Report No.183 to document tnis deficiency. As a part of tne resolution of tnis Corrective Action Report, a review will be conducted to insure that all vendor survey reports for the period from July 18, 1973 to the present are on file. An evaluation of the adequacy of the material supplied by Puget Sound Company will be made from the tine of the last satisf actory W6G survey (July 6,1977) to tne time that tney were deleted f rom the list of " approved vendors for Quality Class I .aateri'Is" Septemaer 11, 1973.  ! ACTIOJS 70 PRE O f dEC'JdREWCE Quality Assurance Proceduce do. I aill be revised to include a requirement that survey reports must be prepared within tao weeks of the date of survey. The Quality Assurance ProcdJures Controlling source vendor evaluation and audits have been recently revised. Project quality Assurance will evaluate these procedures for adequacy of logging, filing, and control of required documentation to insure provisions are established to prevent recurrence of this condition. DATE OF FULL COM?LIAUCE l 12/1/30 f 13

e

3. <MG Q;ality Assurance Manual, Section 10, paragrapii 10.3.' states, in part, that "all welding including tack welding is performed by welders qualified as required by Section III and Section IX of the ASME Code." ASMi Section III, paragraphs NX-4321(b) and HX-4321.2 reauire tna welders of teaporary attachments and tack welds to be qualified and that the material used for temporary attachments be cc:apatiala for welJing to the component material and be certified.

JBG 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 perfonned.

Contrary to the above requirements, the weld record packages did not contain idencification of welders or filler metals used for tack welds and tenporary attachments made on pipe spools LPC-756-5.6, LPCS-756-19.21 and LPCS-2271-1. - This is an infraction. ACTIOUS TO CORRECT DEFICIENCY The date and locations of all te.aporary actacnments, welder, ano weld filler metal identification are recoroed on Form WF-2d6. A review of all work packages requiring traceaoility will be conducted to determine when the NF-286 f orm is reTa i red. Copies of the required NF-286 forms will be incorporated into tne work packages. IR's will be issued wnen kF-286 fonas are required but not located. Inspection reports have been written on the weld record packages fc r oipe spools LPCS-756-5.6, LPCS-756-19.21 and LPCS-2271-1. ACTIONS TO PREVEaf RECURiOJCE Work Procedure no. 42 has oeen revised and now provides for recording tne welder identification, weld process, and identification of the filler material for tenporary attacn.:ients and tac < welds on tua wurs package weld material. DATE OF FULL CUM?LI M E 1/1/31 s t W 14

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