ML17272B001
| ML17272B001 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/17/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17272A999 | List: |
| References | |
| REF-SSINS-6020 EA-80-020, EA-80-20, NUDOCS 8006240090 | |
| Download: ML17272B001 (14) | |
Text
APPENDIX A NOTICE OF VIOLATION Docket No.'0-397 Construction Permit No.:
CPPR-93 EA-80-20 Based on the results of NRC investigation conducted between November.27, 1979 and February 28, 1980, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Facility License No.
CPPR-93.
The NRC investigation revealed significant deficiencies in your quality assurance program, in that work performed by contractors and subcontractors did not conform to the criteria of 10 CFR Part 50, Appendix B, as described in Appendix D of your PSAR.
Specifically, as of November, 1979, the items listed below had not been identified nor corrected.
I.
Items of Noncompliance Relating to the Sacrificial Shield Mall A.
10 CFR 50, Appendix B, Criterion V, states that "Activities affecting quality shall be prescribed by 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 appropriate quantitative or qualitative acceptance cr iteria for determining that important activities have been satisfactorily accomplished."
Paragraph D.2.5.5 of the gA Program states in par t, that "Activities
'affecting quality
. shall-be accomplished in accordance with these instructions, procedures, or drawings The erection of the reactor building sacrificial shield wall is prescribed, in part, by drawing No. 2808-5836, Revision 2, Note NN, which states, in part, Each segment shall now be attached to the lower SSM by welding columns to inner and outer column splice plates and slot welding bottom segment ring beam to top of box ring beam.
. also remove temporary shims before welding Contrary to the above requirements, on June 14,
- 1978, assembly of the sacrificial shield wall in the reactor building was completed with tempora'ry shims still in place at the interface of the bottom segment ring beam and the top of the box ring beam.
These shims prevented several slot welds from joining the ring beams.
Thi.s Violation resulted in the as built structure being incapable of performing its intended safety function during design basis earth-quake conditions and certain postulated pipe break accidents (Civil Penalty - $5000.00).
S OOSS 4OO~O
Appendix A
B.
10 CFR 50, Appendix B, Criterion XI states "A test program shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures Paragraph 2.5. 11 of the gA Program states in part, "Test procedures shall include provisions for assuring that prerequisites for the given tests have been met 1.
The fabrication, erection, and testing of the sacrificial shield is prescribed in part by MPPSS Contract Specification No. 2808-215.
Appendix D of this specification, entitiled "Technical Documentation and Procedure Requirements"
- states, in part, that "
Document (including test procedures) is to be submitted for approval and must be approved or approved as noted by owner before affected work can proceed Contrary to the above requirements, ultrasonic testing of the weld joints listed below was performed before an owner-approved procedure was provided.
~Com onent Ring beam 113B 113C Weld Joint Joints 23, 24 Joints 31,32 114C Joints 23, 24 Date June 17, 1976 Box Column 29B 29A Joints 21-28 Joints 1-8 June 16, 1976 Meld Maps M45 M21 M22 M22 Joints Joints Joints Joints July 24, 1976 9-10 1-6; 8-10, 12, 13 1-4, 6-8, 10, ll 12, 13, 167 15, 16, 22, 132, 140 30,
- 168, 144, 32, 33, 35, 37, 166 Electro-Slag X-100 X-102 June 2, 1976 The contractor's ultrasonic test procedure (equality Control Procedure 8.0, Rev.
1, "Ultrasonic Testing" ) was approved by the owner (owner's agent) on September 27, 1976.
This nonconforming condition was not identified nor were the weld joints retested after an approved procedure was provided.
This is an Infraction (Civil Penalty
$3000.00).
Appendix A
"3-2.
The fabrication, erection, and testing of the sacrificial shield wall is prescribed in part by MPPSS Contract Specifica-tion No.
2808-215 which requires that nondestructive testing personnel be qualified in accordance with the requirements of the American Society for Nondestructive Testing Recommended Practice No. SNT-TC-lA (Third Edition).
SNT-TC-1A specifies that individuals who read and interpret indications (test results) shall be certified NDT Level II or III and that the certification is not transferable between employers.
For certification, as a
NDT Level II, an individual must be administered a general written examination (covering basic test principles);
a specific written examination (covering equipment, operating procedures, and techniques);
and a practical examination (to demonstrate operation of equipment and analysis of resultant information).
The practical examina-tion should include at least 10 different check points.
- Further, an individual certified as a
NDT Level III shall be responsible for conducting and grading examinations of NDT Level I and II personnel.
Contrary to the above requirements:
a ~
An individual, who was never qualified by the contractor, performed nondestructive ultrasonic testing on the sacrificial shield wall plates Nos.
b56 and f56 on June 2,
1976.
b.
An individual performed ultrasonic testing (UT) on the sacrificial shield wall ring beam 113b, welds 23/24 on June 17, 1976; ring beam 1146, welds 15/16 on June 17, 1976; subassemble 56b for segment 22A, welds 212 to 235 on June 17, 1976; box column 29b, welds 21 to 28 on June 16, 1976; ring 3 dwg 56, welds 100 and 102 on June 2, 1976; ring 8, pc 252c, weld 115 on August 4, 1977, and others without having taken a practical examination which was in accordance with SNT-TC-1A.
Specifically, no check points were defined or applied to the examination as required by SNT-TC-lA, and the examination document did not demonstrate that an individual certified as a
NDT Level III conducted or graded the examination.
This is an Infraction '(Civil Penalty - $3000.00).
C.
10 CFR 50, Appendix B, Criterion IX, states
-that "Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable
- codes, standards, specifications,
- criteria, and other special requirements."
Appendix A
Paragraph 2.5.9 of the gA Program states:
"Measures shall be established and documented by the contractor 'to assure that special
- process, including welding, heat treating,
- cleaning, and nondestruc-tive examination, are accomplished under controlled conditions in accordance with applicable
- codes, standards, specifications, criteria and other special requirements, using qualified personnel and proce-dures.
Documentation shall be maintained for currently qualified personnel, processes, or equipment in accordance with the requirements of pertinent codes and standards.
For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined."
The fabrication of the sacrificial shield wall is prescribed in
- part, by WPPSS Contract Specification No. 2808-215.
This document specifies that welding shall be in accordance with the AWS Structural Welding Code D.l.1-1974.
1.
Paragraph 3.7.2.4 of the Structural Welding Code states, in part, that for the repair of cracks in welds or base metal,
. Ascertain the extent of the crack by use of acid etching, magnetic particle testing or other equally positive means:
remove the crack 'and sound metal 2 inches beyond each end of the crack; and reweld Contrary to the above requirements, repair instructions and completion signatures dispositioning "Incomplete/Rejection Tags" Nos.
- 5257, 5325,
- 5412, 6055,
- 6056, 6058,
- 6059, 5443,
- 5444, 5445,
- 5446, and 5447 demonstrate that the repairs made to cracks in shield wall subassemblies during the period of April 1976 to April 1977 were made without using acid etching, magnetic particle testing, or other positive means to define the cracks, and sound metal 2 inches beyond each end of the cracks was not removed as required by the code.
This is an Infraction (Civil Penalty - $3000.00).
2.
Paragraph 3.4.3 of the Structural Welding Code states, in part, that ".
The contractor shall develop weld sequences which will produce members and structures meeting the quality require-ments specified.
These sequences and any revision necessary in the course of the work'hall be sent for information and comment to the engineer Contrary to the above requirements, as of December 7,
1979 the weld sequences developed by the contractor and used during fabrication of the shield were not submitted to the engineer (Burns 8 Roe, Inc.).
These weld sequences are delineated in a
Appendix A
document, entitled, "Sacrificial Shield Mall Assembly Procedure" which was an informal document, not signed or controlled by the contractor.
This is an Infraction (Civil Penalty - $3000.00).
3.
The Structural Melding Code.
Paragraph 3.7.3 of this.code,
- states, in part, that "
Members distorted by welding shall be straightened by mechanical means or by carefully supervised application of a limited amount of localized heat.
The temperature of the heated areas as measured by approved methods shall not exceed 1200F Contrary to the above requirements, no documented instructions, procedures, or drawings were provided to control the application of localized heat during the straightening of each segment of sacrificial shield wall ring beam No.
3 and segment 2A of ring beam No. 2, and other shield wall components as documented on manufacturing Order Nos.
- 00094, 000913,
- 000916, 1193,
- 1666, and others during 1976.
Control of the maximum temperatures in the heated areas was not assured nor is there documentation of the methods used to measure the temperature or the actual temperatures reached during this activity.
Temperature control during the heat straightening process is important in assuring retention of the as built physical properties of the material.
This is an Infraction (Civil Penalty - $3000.00).
D.
10 CFR 50, Appendix B, Criterion XVII, states that "Sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following:
operating logs and the results of reviews, inspections,
- tests, audits, monitoring of work performance, and materials analyses.
The records shall also include closely related data such as qualifica-tions of personnel, procedures, and equipment.
Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location and assigned responsibility.
Paragraph 0.3.4. 17 of the gA Program states in part, that "Sufficient records will be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality The Records
- include, as a minimum, the results of reviews, inspections,
- tests, audits, monitoring of work performance.
Appendix A Inspection and test records will, as a minimum identify the inspector or data recorder, the type of observation, the results, the accepta-bility, and the action taken in connection with any deficiencies noted.
Required records will be identifiable and retrievable Contrary to the above requirements:
l.
On January 24, 1980, quality records were not retrievable which identify the individuals who performed many of the visual inspections on the shield wall, as indicated by the following examples:
a ~
Shield wall manufacturing orders for pieces al5, 15c, dl5, gR14, tll3, 14V and b17 (no serial numbers had been recorded on these manufacturing orders) documented inspec-tions performed by inspector No.
7 between January 16, 1976 and March 1, 1976.
The contractor has no records available to provide the identity of this individual.
b.
Shield wall Manufacturing Orders
- 000515, 000631,
- 1606, 1249,
- 1263, and 1569 document inspections by inspector No.
4 in May and June 1976.
The contractor has no records available to provide the identity of this individual.
C.
Shield wall Manufacturing Orders
- 2000, 2002,
- 2020, 1866 and 1945 document inspections by inspector No.
6 in August 1976.
The contractor has no records available to provide the identity of this individual.
The lack of the above records does not permit verification that the inspections were performed by qualified personnel.
This is an Infraction., (Civil Penalty
$3,000.00) 2.
On January 23, 1980, information contained in quality records was inconsistent and did not accurately reflect activities performed on the shield wall as indicated by the following examples:
a.
Shield wall ultrasonic test report for piece No.
113/78.is not dated and results of testing are not indicated.
b.
Shield wall Manufacturing Order No.
000917 indicates that welds 1-4 on drawing 75 were performed using welding procedure No. 0001-13-06 (the electroslag welding process);
the weld map for these welds indicates the welds were made using procedure No. 0001-01-10 (the shielded metal arc welding process).
Appendix A C.
Two shield wall weld maps Nos.
M256 exist.
One map indicates welding electrode serial Nos.
A383ER/029092 were used to make welds 4, 5, and 6; the second map indicates electrodes Nos.
A383ER/036084 were used to make the same welds.
The above noted omissions and inconsistencies resulted in records which do not provide assurance that these activities were satisfactorily performed.
This is an Infraction (Civil Penalty - $3000.00).
II.
Items of Noncompliance Relating to Pipe Mhip Restraints A.
10 CFR 50, Criterion IX states:
Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive
- testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable
- codes, standards, specifications, criteria, and other special requirements.
10 CFR 50, Criterion XI states:
A test program shall be established to assure that all testing required to demonstrate that structures,
- systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
The test program shall include, as appropriate, proof tests prior to installation, preoperational
- tests, and operational tests during nuclear power plant or fuel reprocessing plant operation, of structures,
- systems, and components.
Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions'est results shall be documented and evaluated to assure that test requirements have been satisfied.
Paragraph D.2.5.9 of the gA Program states:
Measures shall be
-established and documented by the contractor to assure that special processes, including welding, heat treating,
- cleaning, and nonde-structive examination, are accomplished under controlled conditions in accordance with applicable
- codes, standards, specifications, criteria and other special requirements, using qualified personnel and procedures.
Documentation shall be maintained for currently qualified personnel, processes, or equipment in accordance with the requirements of pertinent codes and standards.
for special processes not covered by existing codes or standards, or.where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined.
Appendix A
Paragraph D.2.5. 11 of the QA Program states:
A test program shall be established to assure that all testing required to demonstrate that the item will perform satisfactorily in service is identified and documented, and that the testing is performed in accordance with written test procedures which incorporate or reference the require-ments and acceptance limits contained in applicable design documents.
The test program shall cover all required tests, including as appro-priate, prototype qualification tests, proof tests prior to installa-tion, preoperational
- tests, and operational tests to verify continued satisfactory performance during operation.
Test requirements and acceptance criteria shall be provided by the organization responsible for the design of the item under test, unless otherwise designated.
Test p'ocedures shall include provisions for assuring that prerequisites for the given test have been met, that adequate instru-mentation is available and used, and that necessary monitoring is performed.
Prerequisites include such items as calibrated instrumen-tation, appropriate equipment, trained personnel, condition of test equipment and the item to be tested, suitable environmental conditions, and provisions for data acquisition.
Test results shall be documented and evaluated to assure that test requirements have been satisfied.
1.
The fabrication of safety-related pipe whip restraints is prescribed in part by WPPSS Contract Specification No. 2808-90.
Division 5, Section 5A, "Technical Specifications for Pipe Whip Restraints,"
Paragraph
- 3. 8. 2, of the contract specification
- states, in part, that "
. Contractor shall submit to owner
. all quality assurance procedures required
. Contractor shall not proceed with the affected work until its procedures have been approved by the owner."
Contrary to the above requirements, ultrasonic testing.was performed on pipe whip restraints Nos.
PMS 30-5, PMS 27-17, and PWS 6-1 in September and October 1976 before owner-approved procedures were provided.
Contractor procedures for this work (QCP 8.0, Revision 0, "Nondestructive Testing Procedure for Ultrasonic Inspection;"
QCP 8. 2, Revision 0, "Qualification and Certification Procedure for Nondestructive Test Personnel;"
and QCP 8.4, Revision 0, "Nondestructive Test Qualification Criteria" )
were approved by the owner (owner's agent) on November 8, 1976.
This nonconforming condition was not identified nor were the weld joints retested after an approved procedure was provided.
This is an Infraction (Civil Penalty - $3000. 00).
2.
The testing of safety-related pipe whip restraints is prescribed in part by Contractor Procedure No.
QCP 8.0, Revision 0, "Nonde-structive Testing Procedure for Ultrasonic Inspection."
Paragraph 4.4 of this Procedure,
- states, in part, that ".
. Before the angle beam examination, the area of the base material through
Appendix A
which sound will travel in angle beam examination shall be completely scanned with a straight beam search unit to detect any reflectors which might affect the interpretation of angle beam results Contrary to the above requirements, the ultrasonic test records for safety-related pipe whip restraints Nos.
PWS 315-5, 315-6, 315-7, and 315-8, dated June 21, 1978, indicate that only angle beam examination was performed.
This is an Infraction (Civil Penalty
$3000.00).
3.
The fabrication and testing of safety-related pipe whip restraints is prescribed in part by MPPSS Contract Specification No. 2808-90 which requires that nondestructive testing personnel be qualified in accordance with the requirements of the American Society for Nondestructive Testing Recommended Practice No.
SNT-TC-1A (Third Edition).
SNT-TC-1A specifies that individuals'ho read and interpret indications (test results) shall be certified NDT Level II or III and that the certification is not transferable between employers.
For certification as a
NDT Level II, an individual must be administered a general written examination (covering basic test principles);
a specific written examination (covering equipment, operating procedures, and techniques);
and a practical examination (to demonstrate operation of equipment and analysis of resultant information).
Contrary to the above requirements:
'a ~
An individual, who was never qualified by the contractor, performed the required nondestructive magnetic particle testing on pipe whip restraints Nos.
PWS 27-1, 27-5, 28-1, 28-2, 31-4, 32-3, and 33-4.
equality records for these tests are dated August 17, 1976, August 17,
- 1976, August 17, 1976, August 17, 1976, August 19, 1976, August 19, 1976, and August 25, 1976 respectively.
b.
An individual, who had not taken a "specific" written examination for magnetic particle testing as required by SNT-TC-lA, performed the required magnetic particle testing on pipe whip rest'raints PMS.36-8 on August 4, 1976, PWS 36-12 and PWS 36-13 on August ll, 1976, and others.
This is an Infraction (Civil Penalty
$3000.00).
Appendix A 4.
WPPSS Contract Specification No.
2808-90 for safety-related pipe whip restraints specifies that work shall be done in accordance with the AWS Structural Welding Code D. 1. 1-1974.
Paragraph 3.7.3 of this code, states, in part, that "
Members distorted by welding shall be straightened by mechanical means or by carefully supervised application of a limited amount of localized heat.
The temperature of the heated areas as measured by approved methods shall not exceed 1200F Contrary to the above requirements, no documented instructions, procedures, or drawings were provided to control the application of localized heat during the straightening of pipe whip restraints subassemblies as documented on Manufacturing Order Nos.
- 0710, 0726,
- 0730, 0735 and 0736 during August and September 1976.
Control of the maximum temperatures of the heated areas was not assured nor is there documentation of the methods used to measure the temperatures or the actual temperatures reached during the activity.
Temperature control during the heat straightening process is important in assuring the as built physical properties of the material.
This is an Infraction (Civil Penalty - $3000.00).
B.
10 CFR 50, Appendix B, Criterion XVII, states that "Sufficient records shall be maintained to furnish evidence of activities affecting quality.
the records shall include at least the following:
operating logs and the results of reviews, inspections, tests audits, monitoring of work performance, and materials analyses.
The records shall also include. closely related data such as qualifications of personnel, procedures, and equipment.
Inspection and test records
- shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration,
- location, and assigned responsibility."
Paragraph D.3.4. 17 of the gA Program states in part, that "Sufficient records will be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality The Records
- include, as a minimum, the results of reviews, inspections,
- tests, audits, monitoring of work performance Inspection and test records will, as a minimum, identify the inspector or data recorder, the type of observation, the results, the accepta-bility, and the action taken in connection with any deficiencies noted.
Required records will be identifiable and retrievable II
Appendix A
- ll-Contrary to the above requirements:
1.
On January 24, 1980, quality records were not retrievable which identify the individuals who performed many of,the visual inspections on pipe whip restraints as indicated by the following examples:
a ~
Pipe whip restraint Manufacturing Order No.
0457 for PMS 53-15 documents inspections performed by inspector No.
6 on August 13, 1976.
The contractor has no records available to provide the identity of this individual.
b.
Manufacturing Orders 0213 and 0686 for restraints PMS 53-1 and 54-14 document inspections performed by an inspector No.
9 on July 21-22, 1976.
The contractor has no records available to provide the identity of this individual.
The lack of the above records does not enable verification that the inspections were performed by qualified personnel.
This is an Infraction.
(Civil Penalty - $3,000.00) 2.
On January 23, 1980, information contained in quality records was inconsistent and did not accurately reflect activities performed on safety-related pipe whip restraints as indicated by the following examples:
a ~
Magnetic particle test reports for PMS 36-23, 52-8, 36-1, 35-5B, 34-5B, and 32-7 contain data and inspection results written by one inspector and bear the photocopied signa-ture of a different inspector (the two individuals reported that they did not collaborate on the inspections involved).
b.
Ultrasonic test reports for restraints Nos.
PMS 1-1 and 2-1 reported that the ultrasonic testing was performed on October 5, 1976 after post weld heat treatment (PMHT); the manufacturing orders for the same restraints recorded PMHT as occurring on October 6, 1976.
This is an Infraction.
(Civil Penalty - $3,000.00) 3.
Manufacturing Order No.
0750 for restraint No.
PMS 53-14 documents that inspector No.
5 performed magnetic particle testing on the restraint on September 24,
- 1976, whereas the test report for that restraint bears the photocopies signature of a different inspector.
This is an Infraction.
(Civil Penalty - $3,000.00)
Appendix A 4.
Magnetic particle inspection report for restraint PMS 36-9 reports that the testing was performed on welds 6 and 7 on August 4, 1976;
- however, the record bears the photocopied signature of an inspector who was not hired until August 16, 1976.
This is an Infraction.
(Civil Penalty - $3,000.00).
III. Items of Noncompliance Relating to Recent Construction Activities A.
1C CFR 50, Appendix B, Criterion V, states that "Activities affecting quality shall be prescribed by 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 appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Paragraph 0.2.5.5 of the gA Program states, in part, that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings 1.
The control of welding filler material, an activity affecting quality, is prescribed for the prime site piping contractor (Contract Specification No. 2808-215) in his Mor k Procedure No. 1, Revision 20, "Issuing and Control of Meld Filler Material".
Paragraph 5.8 of this procedure,
- states, in part, that "
Portable rod ovens shall be connected to a reliable electric source during the shift.
The pink copy of the Form NF-69 must remain with the rod until the rod is consumed or restocked Contrary to the above requirements:
a.
On February 25, 1980 in reactor building room 3C at elevation 548, the subject contractor had a portable rod oven containing Type E7018 low hydrogen weld rod which was open and not connected to a power source.
The weld rod was at ambient temperature, and the welder was not in the area.
b.
On January 16, 1980, two unused coated electrodes and one partial length coated electrode were lying loose, unattended and not contained in a portable oven at eleva-tion 540 in the reactor containment building.
Melding in this area was under the control of the subject contractor.
The filler material withdrawal form NF-69 was not in the vicinity of the electrodes.
Appendix A C.
On January 17, 1980, six unused Type 7018 coated electrodes were similarly lying loose at elevation 560 in the reactor containment building.
The filler metal withdrawal Form NF-69 was not in the vicinity of the electrodes.
This is an Infraction.
(Civil Penalty
$3000.00).
2.
The fabrication and inspection of safety-related pipe hangers is prescribed in part by the prime site piping contractor's instructions delineated in equality Control Procedure Number 24, Revision 8 (entitled "Hanger Inspection-Traceable Systems",
gCP-24) and Project Directive No. 75, Revision 4, (entitled "Hanger Engineering Standards",
PD-75).
Paragraph
- 10. 2(A) of gCP-24 states, in part, "Visually inspect all welds
. Meld size less than shown on as-built hanger is unacceptable Paragraph 7.5 of PD-75 states, in part, that "The configuration of supports shall be in accordance with the as-built hanger detail "Paragraph
- 10. 1. 2 reiterates that "Unacceptable conditions are weld size less than shown on as-built Contrary to the above requirements, on February 26,
- 1980, safety related pipe hanger No.
HPCS-48 had received quality control inspection by the subject contractor and was considered acceptable, yet the hanger had one fillet weld that was 1/16 inch undersize, and a rigid strut and its mounting bracket were oriented 90 degrees from the configuration shown on the as-built drawing.
This is an Infraction (Civil Penalty - $3000.00).
3.
The requirements for designating inspection requirements and documenting inspections for safety-related pipe supports are prescribed in part by the prime site piping contractor's instructions delineated in Project Directive No. 75, Revision 4 (entit'led "Hanger Engineering Standards",
PD-75) and equality Control Procedure Number 24, Revision 8 (entitled "Hanger Inspection-Traceable Systems",
gCP-24).
Paragraph 5.3 of PD-75
- states, in part, that "Engineering shall indicate the NDE and visual inspection required for traceable systems."
Table 1, page 5A, of the same document specifies magnetic particle (MT) or liquid penetrant (PT) examination of ASt<E Section III, Class II, attachment welds to pressure parts.
Paragraph
- 10. 2(A) of gCP-24 states, in part, "Visually inspect all welds
- Further, paragraph 10.3 of gCP-24 states, in part, that "If the welds are acceptable
. initial, stamp and date the applicable box on the NF-6A.
Assure that all NDE requirements and any A. I. 'Hold'oint have been satisfied
Appendix A Contrary to the above requirements, on February 26, 1980, for pipe support No.
LPCS-12, engineering had not indicated the NDE and visual inspection requirements for lug weld number 6 on pipe support LPCS-12 nor had a quality control inspector initialed, stamped, or dated the applicable inspection box on the NF-6A form for this weld (other quality records,
This is a Deficiency (Civil Penalty - $1000.00).
The requirements for protecting safety-related instrument tubing are prescribed, in part, by the prime site electrical contractor's Procedure CP208 which states under General Maintenance Requirements
- that,
..covers,
- caps, plugs and other closures shall be maintained intact This procedure goes on to state
..dust coverings,
- shrouds, local sealing, heating methods and mechanical cleaning shall be employed to keep the structure as clean and dry as possible II Contrary to the above requirements, on February 28, 1980, safety related instrument rack No.
H22-P005 had three sections of tubing which had been disconnected with the ends left open, exposing the internals of the system.
This is an Infraction.
The failure to properly cover, cap, or plug safety-related instrument tubing was cited previously as an item of noncompliance in IE Inspection Report Wo. 50-397/
79-16.
(Civil Penalty - $4000. 00).
This Notice of Violation is sent pursuant to the provisions of Section 2.201 of the NRC's "Rules of Practice,"
Part 2, Title l0, Code of Federal Regulations.
The Washington Public Power Supply System is hereby required to submit to this office within twenty days of the receipt of this Notice, a written statement or explanation in reply, including for each item of noncompliance:
(1) admission or denial of the alleged item of noncompliance; (2) the reasons for the item of noncompliance, if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further items of noncompliance; and (5) the date when full compliance will be achieved.