IR 05000508/1980013
| ML19345G300 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 12/10/1980 |
| From: | Bishop T, Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19345G298 | List: |
| References | |
| 50-508-80-13, 50-509-80-13, NUDOCS 8103180093 | |
| Download: ML19345G300 (17) | |
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O U. S. NUCLEAR RE',,','JLATORY CC108.ISSICN OFFICE OF INSPECTION AND ENFoRCEME!.T
REGION V
50-508/80-13 Report No.
50-509/80-13 Docket No.
50-509 2 50-509 License No. Cooo-1ca and -1cc Safeguards Group Washington Public Power Supply Syste':1 Licensee:
P. O. Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear projects Nos. 3 and 5 (WNP-3/51 Inspection at: WNP-3/5 Site. Elma, Washinoton
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Inspection comeucted:
September 29 - October 30, 1980
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Inspectors:
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uisnop, v. rtesicent tr..s pec to r Date signed Date Signed Date Signed Approved Ey:
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R. C. Haynes, 'Euref, Projects Section, Reactor Date signed Construction and Engineering Support Branch Surrma ry :
InsDeCtion during the period of SeDtember 29-0Ctober 30, 1980 (Report Nos.
50-508/80-13 and 50-509/80-13)
Areas Inscacted: Routine, unannounced inspection by the resident inspectre of construction activities including: structural steel erection-review of quality implementing documents, observations of work and' work activities, and review of quality records; investigation of concerns related to electrical work and.the pipe hanger program; investigation of allegations related to receiving inspection activities; followup cn project reorganization; tours of site facilities; and follcwup cn previous inspection findings. The inspection involved 76 inspector hours onsite by one NRC inspector.
Results: Of the nine areas inspected, two items of noncompliance were identified and cne continuing item of noncompliance was. identified.
(Failure to properly accomplish bolting, paragfaph 2.b; failure to properly translate design requirements, paragraph 3.a, and failure to properly maintain ec ipment-continuing-; paragraph 8).
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DETAILS 1.
Persons Lontacted
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The inspector interviewed various engineering, management, inspection and' construction personnel of the organizations listed belcw.
. Key personnel including those who attended the exit interview are soecifically identified below.
a.
Washington Public Power Sucoly System (WPPSS)
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D. E. Dobson, Froject Manager, WNP-3/5
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C. E. Love, Deputy Division Manager, WNP-3/5
- *J. C. Lockhart,. Project. Quality Assurance Manager 0. E. Trapp, Project-Engineering Manager
- R. A. Davis, Sr. Project Quality Engineer
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R.! Hicks, Sr. Project Quality Engineer J. Walker, Sr. Quality Engineer
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b.
- Ebasco Services, Inc. (Ebasco)
.*A. M. Cutrona, Deputy Project' Quality Assurance Manager-T. E. Cottrell, Sr. Resident Engineer
- L. F.. Adams, Sr. Project-Quality Engineer
- L. A. Bast, Project Quality Engineer
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Ellis, Sr. Civil Engineer-c. - Morrison-Knudsen, Inc. (MK)
'F. C. Edler, Project-Quality Manager.-
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d.' Peter Kiewit Sons' Company (PKS)
' D.'Paulsen, QA Manager
- Denotes those present at the NRC exit interview on October 30,
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-1980. ~0ther caitEinterviews were held on October.16 and 24,
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'1980. ' Also, Mr.- G.; Hansen,- Senior Project Ecsineer for the State
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ofyWashington, Energy. Facility. Site Evaluation Council, was also
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~ in' contact with the inspector during the month,
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- 2.
Licensee ' Action on Previous Inspection Findings e
'a.
(Ocen) 50-509/80-06-03, Noncomoliance-Failure to procerly acccmolish and inspect welding (MK)
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The licensee's: response rto this item of noncompliance:is' documented r
In' WPPSS: letter.No. G03-80-2364-of September._26,11980. - The~ actions-7 aken = included ' repair, nondestructive examination, and reinspection t
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i of'the specific; weld cited in the item of noncompliance; additional Ltrainingoffpersonnel;andprocedural-changes-tomoreclearly
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-2-define inspection and documentation of structurcl steel connections.
The inspector verified that the repair, training, and procedural changes had been satisfactorily acccmplished.
In examining the records of the nondestructive examination (NDE) it was found that the NDE report addressed only arc strikes and not the post repaired weld. The report was subsequently corrected and appro-priately annotated by the person who performed the NDE to clearly document that the repaired weld was examined and found to be satisfactory. The insoector visually examined the weld and found it to comply with AWS D1.1 code requirements.
After the. original item of noncompliance was issued, a secic.d weld deficiency (oversized weld) was identified by the NRC inspector.
This condition was documented in NRC inscection report No.
50-508/509/80-08 and reported as a continuation of the original item of noncompliance. The axamination of licensee acticn on this particular item established that personnel training regarding the oversized weld nad been accomplished but that the condition
- had not yet been cocumented on a nonconformance report and evaluated fc-tecnnical acceptability. The item of noncompliance, therefore, remains coen penaing completion of this action.
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b.
(Ocen) 50-508/509/80-06-02, Noncomoliance-Failure to establish measures to incicate inscection status (MK)
The licensee's response to the item of noncompliance is documented in '!PPSS letter lio. G03-80-2354 of September.26, 1980. The actions
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taken include proper rebolting of the structural steel joint in cuestion; additional training for cognizant inspection personnel; and procedural changes to require as-built drawings of ali structural steel connections.
It was intended that the "as-building" of the structural steel would assure that each joint receives an appropriate inspection. The inspector verified that th? specific joint in. question had been properly rebolted, and that the procecoral changes and training had been accomplished.
The inspector found, however, that the contractor did not apply the requirement for "as-building" retroactively.
It should be noted that the example cited in the NRC Notice of Violation, which ~ demonstrated the lack of measures -to control inspection status, involved a joint assembled several months ago (approximately Janua ry, 1980). A contractor management representative explained that all structural steel erections subsequent to July 11, 1980, would be "as-built" and that a' records review would be performed to. assure that all joints assembled prior to.that date had. received inspection. The representative stated ~ that contractor procedure No. AI-9, entitled " Quality Assurance Records Control F*ocedure",
provided for the records review.
Examination of procedure Tha. AI-9 revealed that the: procedure only addresses record control in generai, and does not specifically identify. the measures that
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will be used to assure.that all joints assemoled before July 11, 1980 bave been properly ins ectad. Accordingly, this. item remains open ending action..'.ich ' assures.all structural steel joints will have been procerly inspected.
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fi-3-In examining the effectiveness of the corrective measures taken, the inspector examined two completed (and "as-built") structural
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steel areas 'in Unit 3 reactor auxiliary building (documented
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in record packages Nos. 3 ABS-007-390 anc 3 ABS-017-390) and one area in Unit 5 reactor auxiliary building (documented in record
package No. 5 ABS-002-362). No concerns were identified for the Unit 3 structural steel.
Inspection of tne Unit 5 structural steel on October 22, 1980 revealed two joints which contained loose bolts. Quality records for these assemblies (be:ms 2953
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to 2938 and 291F/292E to 39A) show that inspection reports had
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1980, respectively) and that the "as-built" drawing had been developed and' stamped by the QC inspector. Contractor representatives
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were of the optnion that the crafts had loosened the joints some time following the QC inspector's final inspection. However,
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it is apparent.that the corrective measures, as. implemented, do not assure that all structural steel joints are assembled, inspected, and maintained in accordance with specification i
requi rements'. The failur? to assure that bolted assemblies meet-specification requirements is contrary to the requirements of 10 CFR 50, Appendix B, Criterion V.
This is an apparent item cf r.oncemoliance (50-508/509/80-13-01).
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c.
(Closed) 50-503/509/80 09-02, Unresolved Item - Turbidity
.in heatec concrete mix water (ASG)
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Laboratory _ testing (Gennett Laboratories report of September 29,
- 1980) of the quality 'of heated. water ~ used for concrete mixing -
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revealed that turbidity level off the water'was within specification
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limits. it was noted, however, that.the pH of the water was measured as 8.05 whereas the specified' allowable range.for pH E
is 6.0-8.0.
This was adequately.taken care of by the contractor by using this water for non-quality class concrete. The inspector
- had no.further questions.ori this. matter.
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~(Closed) 50-508/509/80-09-03, l'nresolved item - Inconsistencies in concre+.e mi[ water chlorice' level test results (PTL)
Licensee and contractor: investigation lato the inconsistencies
. - ~in water: chloride levels indicate the-differences may be due to differences ~ in1the. test ' methods.used, possible contamination of one of the. samples, or possible analytical erroriin the calculations.
.The' calculations'were rechecked ano found' to be : correct.- The chloride. levels repcrted are well with allowable limits 1(7.5
<to 21 ppm' actual versus'100 pom allesed;in free water and 250 ppm in extracted water). indicating.there is no' technical concern withithe actual chloride levels. The inspector has.no further -
[ questions on'this matter at this, time.
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3.
Structures (Structural Steel and Succorts)
a.
Review of Ouality Imolementino Documents Tne inspector selected eight contract drawings relating to
E structural steel erection of the Unit 3 and 5 reactor auxiliary building slabs at elevations 365.5 ft. and 390 ft.
rom these drawings the inspector selected five beams for further analysis. The Jetailed contractor drawings for the five selected beams (drawing / beam Nos. Fought 341A, 248A, 350B, 341C, and 304C) identified the bolting configuration to be used in securing the ends of the beams. Using the beam end connection reaction loads provided on the contract drawings and the joint configurations identified on the detailed contractor drawings, the average bolt stress was computed to assess the technical adecuacy of the drawings. The
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ccmoutea bolt loadings were comparea against the requirements of the PSAR, AISC High Strenpth Bolting Specification-1972,
. the contract scecification Gio.3240-95, entitled " Structural Steel - Phase I) anc referenceo Project Specifications (Nos.
3240 aa8, entitled " Structural Steel", and 3240-50lWa, entitled "High Strengtn Bolteo Field Connections for Structural Steel").
The results of the examination are provided below:
CcmLted Actual Design Spec 50lWa AISC-1972 Spec 50lWa/
-Boit Stress Configuration / Allowable Stress -Allcwable Stress 448 Specified-Connection (?SI)
Eolt Tyoe (?SI)
(PSI)
Design Config.
1) 341A~to 412B 20,i00 Friction /A430 15,000 20,000/A490 FRICTION 2) 248A:to 407B 18,450 Friction /A490 15,000 20,000/A490 FRICTION 3) 350B'to 407A 15,040 Friction /A325 15,000 15,000/A325 FRICTION-4) 341C'to 429A if,280 FrictionFi90 15,000 20,000/A490 FRICTION 5)'304C to'277 17.420 Friction /A490 15,000 20,000/A490 FRICTION The above information indicates that each of the above joints allowed stresses in excess of that permitted by specification 50lWa and that two of the joints slightly exceeded that allowed
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by the AISC High Strength Bolting-Specification-1972, joints
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~1) and 3)'above.
Based on the above, the inspector then selected an additional twenty bolted connections 'for examination.
Of the-twenty connections examined, eight were found to be in excess of the 15,000 psi Jallowable stress of Spec. 50lWa (beams 40A,:41A, 44A, 207E, 206B, 48C, 343C, and 49A), one wasifaund to have bolt stresses in' excess of that allowed by the AISC Specification (Seam 207E, bolt stresses of 15,120 psi vs.15,000 psi), and three joints were designed as " bearing" type connections (Beams 40A, 41 A, and 44A with bolt stresses of. 29,200 to 31,900 psi) in 1-;eu of the specified " friction" -
type connections. 'It was furt*.,tr determined that the installing contractor's maality-program: Merrison-Knudsen) did. not specifically provide for inspecting bearing type connections (i.e., ' assuring'
no. threads are in'the boit-shear plane) since their contract
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-5-specification indicated all joints were designed as friction type consctions.
The specified bolting configuration designs depicted on the contractor drawings (Fought drawing Nos.
40, 41, 44, 48, 49, 206, 207, 248, 304, 341, 343, and 350)
had been approved by the licensee's Architect-Engineer.
Pre-liminary investigation inte this situation by ?r.e licensee and AE representatives indicated that each of identified conditions may be technically acceptable. The failure to assure that design bases (stress limitations and joint types)
are translated into the working drawings is contrary to the requirements of 10 CFR 50, Appendix B, Criterion III. This 14 an apparent item of noncompliance (50-508/509/80-13-02).
b.
Observations of Work and Work Activ;'ies t
Structural steel work activities related to completed structural steel work described in paragraph 2.b and inprocess erection activities of Unit 3 370 f t. elev. platform and Unit 5 360.5 f t.
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elav. (south) reactor auxiliary buildings were observed.
The.ceservations included examinations of steel storage, marking, protection, segregation, inprocess inspection, verification that the proper drawings and materials were utilized, and Ethat materials (including fasteners) were properly installed.
The activities-were observed 'for compliance to the requirements of the PSAR, AISC Structural Steel Manual, Specifications
~32a0-252, -448, and -50lWa, pertinent drawings, and the contractor's controlling procedure (CP-05).
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With the exception of the items addressed in paragraph 2.b no items of noncompliance or deviations were identified.
c.
Review of Quality Records The quality records related to materials identified in item
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3.b above, were examined. -These records included inspection reports, as-built drawings, and structural steel checklists (material certifications and inspectors qualifications were previously verified-for this work). The records were examined
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for compliance to the requircments of the PSAR specification, and procedural requirements.
No items of noncompliance or deviations were identified.
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4.
Concern Recardino Documentation of Electrical Work c
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On October 10, 1980 a craftsman with' the prime electrical contractor
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(Fischbach and Moore). contacted the inspector to express concern
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regarding the apparent. lack-of documentation f or ' ongoing electrical
, ork in the Unit:3 reactor auxiliary ouilding. The individual w
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explained -that he was involved in the installation of lighting-and convenience power conduit;in the pump' rooms and believ9d
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-6-that a recent procedure revision (QCP-508 S3, revision 3) required that an installation ticket be completed for such work. When he questioned his foreman about the lack.of a ticket he stated that he was told 'not to worry about it'.
It was determined
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that the work involveo was tecoorary service and, therefore,
did not require the generation of an in:tallation ticket. To preclude future oroblems in this area, the contractor conducted an indoctrination class to discuss attitude and information to the workmen. The inspector has no further questions on this matter.
~5.
Allegation Regardino Receiving Insoection Activities An individual contacted the insoector on October 14,_1980 and cace the _ following allegations:
a.
The WFPSS/ESASCO material. receiving organizatica recantly received a shipment of 13' bolts (aporoximately 1 1/8 incn in ciameter) witn acccmoanying documentation wnich acoresed only 12 of the 13 bolts.
Rather than fill out an '" overage" report, as required by the prccedures, tne OC inspector cirected that the excess bolt be discarded
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b.
A defective beam received at the' site was repaired by sito contractor whereas the supporting documentation f e the repair. indicates the beam was returned to the sucolier for. repair.
Investigation into these two allegations revealed that both were
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^the' subject of!an cngoing licensee investigation which had been initiated prior to October 10, 1980. The licensee investigation had substantiated _ the' first allegation-(failure to properly handle
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excess ' material) and_were still in the process of investigating the second allegation. The beam in question had.been identified (flo. 354E) and has been. subjected to additional nondestructive
. testing which verified the as-repaired beam is satisfactory.
It appears that the licensee's action in reference to the allegations i
thus far is appropriate. This subject will be further examined
'in a' subsequent inspection -(50-508/509/80-13-03).
6.1 Concern Regarding Pice Hancer Program Management On October 16,1980 'the inspector received (indirectly) a concern regarding;the-quality of management for the project pipe hanger program. The individual was subsequently contacted by the. inspector and provided general statements about unnecessary nonconformanc3 reporting and a-lack of code-knowledge for those individuals
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wno.% cite the' reports. _The individual concluded by stating that 7 e _had no specific allegations 'regarding improprieties:within h
-.the: programs. - The. inspectorf stated :that the individual's concerns
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).-cuid be densidered during.the cenduct of. routine inspections
of 'the :nanger program.
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Project Management Reorganization During October, the licensee announced the structuring of WNP-3/5
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project management organization to separate the WPPSS ano ESASCO functions at the site. Licensee representatives stated that the * 3structur:r.g would take olac e over a period of time. The inspector requested additional c'arification regarding the transitic7 plan, definition and control of p-oject interfaces, changes to the PSAR and project instruction, and any personnel indoctrination related to the restructuring / procedural changes to assure retention of control during and folicwing the transition period.
Licensee representative agreed to provide the information.
This topic will be examined further as the transition progresses (50-508/509/80-13-04).
8.
Insoectioniours of Site Faciliti.e-At varicas times during the inspection period the inspector mace tours.cc the Unit 3 and 5 plant island and material storage areas, examining general housekeeping, QC and craft supervisory coverage for work activities, availability of work documents, equipmer.t calibration status, tagging and identification of materials, and protection of installed equipment.
On October 20, 1980, the inspector observed that water = had accumulated under the protective tents for the three Unit 3 charging pumps.
This condition was identified to the licensee on th2t date and the water was removed. On October 23, 1980, water was found lunder-the protective tents again. 'The subject of inplace storage of ANSI level B equienent '(charging pumps) is currently an item of nonccmpliance.
The recent findings:are considered to be a continuation of this item (50-508/509/80-10-02) and will be further reviewed in conjunction with the closecut to the item of noncompliance.
No other-items of noncompliance or deviations were identified.
9.
Exit Interviews Exit interviews were held on October 16 and 24,1980 with a surmary
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meeting on 0ctober 30,.1980. Licensee and EBASCO reprasentatives attending the October 30, 1980 mecting are denoted in Paragraph 1.
' During the meetings, the inspector sunnarized the scope and findings of the iaspection identifying. including the items of noncompliance discussed in paragraphs 2.b, 3.a, and 8.~
Licensee representatives
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Washington Public Power Supply System aT
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A JOINT CPERA?!NG AGENCY
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, o sonm u m.w u e cros e i ruoso.w mmi January 9,1981 G03-81-054
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Nuclear Regulatory Commission, Region V Suite 202 Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California 94596 Attention:
Mr. Chief Reactor Construction ar.d Engineering Support Branch Subject:
WPPSS NUCLEAR r'ROJECTS 3 & 5 NRC INSPECTION OF WNP-3 AND WNP-5 00CKET NUMBERS 50-508 AND 50-509 References:
1).
Letter, to F.D. McElwee, same subject, dated December 12, 1980.
2).
Federal Register Notice (45 FR 66754),
dated October 7, 1980.
Dear Mr. Spencer:
This letter is in response to your letter of December 12,1980, which discussed the results of the inspection conducted September 29 to October 30, 1980, of activities authoriz.d by Nuclear Regulatory Commission Construction Permit Numbers CPPR-154 and CPPR-155 The letter identified two items of nonce.:.pliance categorized in accordance with Reference 2 and required the Supply System to provide a response to these
iten 3 The specific Nuclear Regulatory Comission Findings, as stated in your letter, and the Supply System response are provided in Attachment I to this letter.
Should you have any questions or desire further infomation, please feel free to contact me directly.
Very :ruly yours, Project Manager, WNP-3/5 Attachment cc:
0. Smi thpeter - SPA Ebasco - New York WNP-3/5 Files - Ric.tland 2/-6/
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Attachment 1 Page 1 of 3
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ATTACHMENT I A.
NUCLEAR REGULAYORY COMMISSION FINDING A 10 CFR 50, Appendix S, Criterion III, states, in part, that, " Measures shall be established to assure that applicable regulatory requirements
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and the design basis...are correctly translated into... drawings..."
Paragraph 17.1.3 of the Quality Assurance Program documented in the PSAR states. in part,-that, " Prior to submittal of design documents to either WPPSS or Ebasco for review and/or approval, the design contractors, including Ebasco, are responsible for verifying that the design meets the requirements of the specifications..."
' Contract specification No. 3240-95-(entitled, " Structural Steel - Phase I") specifies that the design for structural steel shall be in accordance with project specification No. 3240-448 (entitled " Structural Steel").
Specification No. 3240-448, paragraph 2.6 states, in part, that, " Field connections'shall be friction type joints..." and that connections shall be in accordance with specification No. 3240-50lWa (entitled "Hi;;h Strength Bolted Field Connections for Structural Steel"). Specification
- No. 3240-50lWa, paragraph 6 states, in part, that, " Joints shall be
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friction type bolted connections detailed for an allowele working stress in shear of 15,000 psi..."
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. Contrary to th'e above, on September 29, 1980, the steel fabricator's design drawings for structural steel beam connections, detailed joint configurations which exceeded the 15,000 psi bult. stress limit of specification 50lWa (Fought drawings. Nos. 40, 41, 44, 48, 49, 206, 207, 248, 304, 341, 343, and 350) and specified the use of bearing type joints, with accompanying shear stresses of 29,200 to 31,900 psi (Fought drawings No.s 40, 41,' and 44). ~ Furthemore, the installing contractor's quality program did not address the inspection of bearing. type joints (i.e., no bolt threads in the shear planes).
-This is a Severity Level 4 violation -(Supplement II).
. B.- NUCLEAR REGULATORY COMMISSION FINDING B 10.CFR 50, Appendix B, Criterion V states, in part, that, "Activitter affecting quality shall be prescribed by -documented instructions...and shall be accomplished in accordance with these instructions..."
Paragraph 17.4.5 of the. Quality Assurance Program documented in the PSAR states, in part, that, " Provisions are made for assuring that all quality related activi-ties on structures...are. performed in accordance with approved instructions..."
Contract specifications Nos. 3240-263, 3240-448, and 3240-50?Wa specify that
' structural steel bolting shall be installed in accordance with ' instructions in the AISC: specification for structural joints using ASTM A325 or A490 Bolts-
'1972-(highstrengtn. bolts). This. instruction requires. that bolting be tightened.
Contrary to the above, on October 22, 1980, the high strength bolts'were loose in the structural joints joining beams 295 B to 293 8 and 219 F/292'E to 39 A at the-362.5 foot elevation in the.htt 5 reactor auxiliary buildings.
These joints had been inspected and accepted on July 19, 1980 and September 19, 1980.
-.This is a Severity-Level 5 -violation :(Suppiament II).
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Attachment 1 Page 2 of 3
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ATTACHMENT I NUCLEAR REGULATORY COMMISSION FINDING A Corrective Steps Taken And The Results Achieved A.1 The design, materials, fabrication erection and inspection of high strength bolted field connections for structural steel are in accor-dance with the AISC Manual of Steel Construction.
This manual permits an allowable working stress in shear of 20,000 psi for A490F bolts.
The connections on this project using A490F bolts were designed for an allowable stress of 20,000 psi.
A.2'
The steel' fabricator's drawings were reviewed by the Engineer to determine if the stress in the bolts of the bearing type connections exceeds the 32,000 psi allowed by the AISC Manual of Steel Construction, Part.'4.
These bearing type connections were designed with maximum bolt stresses in the range of 27,900 to 32,000 psi. The drawing review also determined that the bolts were detailed with sufficient length to preclude having threads in the shear plane. Therefore, these bearing type connections conform with the AISC Manual of Steel Construction.
-A.3 Several of the steel fabricator's drawings were reviewed by the Engineer to determine if the stress in the bolts of the friction type connections exceeds the _15,000 psi allowed for A325F bolts and 20,000 psi allowed for A490F bolts.
In no case did the design stress exceed the allowable stress by more than 1%. A stress of this magnitude will not adversely affect the structural integrity of the connections. Also, the eighth edition of the AISC Manual of Steel Construction permits an allowable stress in shear of 17,5C0 psi for A325 bolts and 22,000 psi for A490 bolts.
In no case does the design stress in the bolts exceed these values.
Corrective Steos Taken To Avoid Further Items Of Nancomoliance A.1 Cesign change document FCR AS-1124 has been initiated to modify Specification 50lWa. This change revises the first two sentences of
~ Paragraph 6 to read, " Joints shall be friction type bolted connections unless otherwise approved by the Engineer.
Bolted friction type connections shall be-detailed for an allowable working stress in shear of 15,000 psi for A325 bolts and 20,000 psi for A490 bolts."
A.2 Since all-nine of the bearing type connections have been erected in both units-at this time, no further items of noncompliance of this-nature can occur,' and revision to erection contractor's procedures is not required.
A.3
.No corrective action will be taken for _this item since it will not affect the _ structural integrity of the connections and does not violate the eighth edition of the AISC Manual of Steel Construction.
Date When Full Comoliance Will Be Achieved -
Full ccmoliance was achieved on October 28, 1980.when FCR-AS-Il24 was approved.
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Attachment I
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ATTACHMENT I
!UCLEAR REGULATORY C0FMISSION FINDING B Corrective Steos Which Have Cecn Taken And The Results Achieved A visual inspection report dated October 23, 1980 identified the referenced joints.
The structural steel joints have been retorqued and inspected in accordance with the centractor's procedure. Contractor craft personnel h:d loosened the joints to facilitate installation of other structural steel members. Joint rework was completed October 29, 1980, and a part of in-process work prior to concrete placement.
Corrective Steos Which Will Be Taken To Avoid Further Violation The Contractor initiated an Interim Procedure Change Notice (IPCN) to Construction Procedure (CP) 05, Revision 5.
This IPCN requires Contractor Engineering to notify Contractor Quality Control when inspected and accepted structural steel connections are to be reworked. Training classes on CP05 were given on October 23, 1980 and November 1,1980. Additional Contractor Quality Control Inspectors have been assigned to monitor the Contractor's compliance with construction procedures.
Date When Full Comoliance Will Be Achieved Full compliance was achieved November 1,1980.
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D. E. 00BSON, Being first duly sworn, deposes and says: That he is the Acting Program Director, WNP-3/5, for the WASHINGTCN PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authori;:ed to submit the fore-going on behalf of said applicant; that he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge.
DATED l.9
, 1981
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On this day personally appeared before me D. E. DOBSON to me known to be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and purposes therein mantioned.
GIVEN under my hand and seal this N
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January 29, 1981 G03-81-254 Nuclear Regulatory Corr. mission, Re9 on Y i
Suite 202, Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California, 94596 Attention: Mr. Gentlemen:
Subjec t:
WPPSS NUCLEAR PROJECTS 3 & 5 NRC INSPECTION OF WNP-3 AND WNP-5 00CKET NU:4EERS 50-508 AND 50-509 Reference: 1). G03-81-054, letter, D.E. Dobson to G.S. Spencer, same subject, dated January 9,1981.
Reference 1 transmitted the Supply System's response to T;otice, of Violation co @ined in your letter dated December 12, 1930. We have
-~ ince discovered that our response to ' Finding B is not totally accurate.
s The purpose of this letter is to correct our response.
The inaccurate statement in Finding B is that full compliance was achieved November 1,1980. This should be corrected to state, " Full compliance will be achieved by January 16, 1981". All other state-ments in our response are correct as stated.
- Every ef fort is made to respond to NRC letters and questions factually.
However, in this case the inaccurate full compliance date was a result
. of incorrect interpretation of the date spe<.ified.for full compliance.
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We sincerely regret this error and we shall inc.. ease our efforts to
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. ensure accuracy of future responses.
To further complete our corrective actions to prevent additional recurrence, training to implement IPCN 94 was completed by January 16,
-1981.
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Jar.ue j 29, 1981
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Mr. GC 3-El - 25 *
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'cle hope this explanation will satisfactorily answer any questicns which may have occurred.
Very truly yours,
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0.E. 00BScri Project Manager, WNP-3/5 cc:
D. Smithpeter - SPA Etasco - tieu York W::P-3/5 Files - ?.ichlar.d
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D. E. 00B50 1, Being first duly sworn, deposes and says: That he is the Acting Progs am Director - WNP-3/S, for the WASHIfiGT0t! PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authorized to submit the fore-going on. behalf of said applicant; that he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge.
DATED
\\. 7_ 3
, 1981.
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STATE OF WASHI?!GTO:1
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On.this day personally appeared before me D. E. 00SSON to me known to be
- the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and purposes therein mer.tioned.
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JGIVEN under my hand and seal thic= J4 day of han,,n_ w 1981.
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REGION V
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1990 N. CALIFORNIA BOULEVARD
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$UITE 202. WALNUT CREE K PLAZA o,,,e WALNUT CREEK, CALIFORNIA 94596
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W2 gj Docket Nos. 50-508 50-509 Washington Public pcwer Supply System P. O. Box 1223 Elma, Washington 98541 Attention: Mr. D. E. Dobson WNP-3/5 Program Director (Acting)
References:
1.
WPPSS letter from D. E. Dobsen to G. of January 9,1981, No. G03-81-054 as amended by letter from D. E. 0cbson to G. of January 29, 1981, No. G03-81-254 2.
NRC letter frca G. to 7. O. McElwee of December 12, 1980, forwarding inspection Report No.
80-13 Gentlemen:
Thank you for your letters, referenced above, responding to the 1: ems of noncompliance cited in our Notice of Violation _ dated December 12, 1980.
In view of the inaccurate infomation submitted in your letter of January 9, and subsequently corrected in your letter of January 29, 1981, I feel it necessary to emphasize that NRC statutory responsioilities require that information provided by applicants / licensees as a part of the regulatory process be accurate and complete to assure sound-decisions -in the interest of. the health and safety of the public.
For this reason, recent changes in our enforcement policy require that your responses.to Notices of Violations issued be submitted under oath or affirmation.
We understand that you have taken appropriate steps to assure that all levels of management in your organization and those of your contractors are aware that accurate and complete information is essential in your written submissions to the NRC.
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- Should you have any questions relating to this matter, I would be glad to discuss them with you.
Sincerely,
{WfW R. H. Engelken
'cc:
R. l.. Ferguson
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