ML17275A562
| ML17275A562 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/15/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17275A561 | List: |
| References | |
| 50-397-80-08, 50-397-80-8, NUDOCS 8009040474 | |
| Download: ML17275A562 (12) | |
Text
APPENDIX A Washington Public Power Supply System P.
0.
Box 968 Richland, Washington 99352 Construction Permit No.
CPPR-93 NOTICE OF VIOLATION Based on the results of an NRC investigation conducted between June 1 through July 25, 1980, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Facility License No.
CPPR-93 as indicated below.
The NRC investigation revealed significant deficiencies in your quality assurance
- program, in that work performed by the contractor, Wright, Schuchar t, Harbor,
- Boecon, Bovee
& Crail, GERI (WBG), did not conform to the criteria of 10 CFR Part 50, Appendix B, as described in Appendix D of your PSAR.
Specifically, prior to June 1980, the items listed below had not been identified or corrected by the project quality assurance organization.
A.
10 CFR 50, Appendix B, Criterion I, and PSAR, Appendix D, paragraph D.2.5.1 states in part that "The p'ersons and organi zations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational
- freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided."
Contrary to the above requirements, on November 15, 1979, your site contractor (WBG) responsible for safety related mechanical const uction and related quality assurance functions, established the authority of the Swing Shift Construction General Superintendent to order the termination of swing shift QA/QC personnel.
Memorandums Nos.
LGB-229 and PWS-063 from the contractor's QC Manager and QA Manager documented this authority of the Swing Shift Construction General Superintendent.
This is an infraction.
B.
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 criteria for determining that important activi ties have been satisfactorily accomplished."
Paragraph D.2.5.5 of the QA Program as delineated in the PSAR states in part, that "Activities affecting quality...shall be accomplished in accordance with these instructions, procedures, or drawings..."
The contractor's "Field Quality Assurance Manual", revision 10 for NPPSS 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 June 9,
1980 the document package for low pressure core spray pump LPCS-P-2 u>hich had been reviewed and accepted by the Quality Assurance Manager's designee on December 10,
- 1979, was incomplete.
Quality records in the package pertaining to equipment bolting and alignment (Forms NF-159) are dated December 11 and 13, 1979.
This is a deficiency.
blBG Quality Assurance Procedure QAP-5, paragraph 1.1, states that the "procedure provides the responsibilities and methods for the control of nonconforming conditions found in...construction activities" and further prescribes in paragraph 3.1.2 that "Quality Assurance, Quality Control, and Quality Engineering personnel shall initiate an inspection report (IR) upon discovery of an apparent discrepant condition. "
The WBG QCI-2 (Non-destructive Testing Procedure for Magnetic Particle Inspection) required in paragraph 5.7 that magnetizing 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.
Contrary to the above requirements, the inspector observed that two surveillance reports, performed by the NBG Level III Examiner, each dated 9-12-79, identified that, during the 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 increasing the amperage from approximately 100 amps per inch to 150 amps per inch.
The report identified this as a noncompliance with specifications and no inspection report was written.
This is a deficiency.
Piping isometric drawings Sll-290-11.20 and SH-297-8.17 identify that these spools are subject to the requirements of the ASME Boiler and Pressure Vessel
- Code, 1971 Edition,Section III, Class III and were identified as quality class 1.
The examination 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,
- 1975, respectively, was ASNE Section VIII.
The liquid penetrant examination reports indicated that the results of these examinations performed on pipe spools SW-290-11.20 and S'W-297-8.17 were evaluated to the acceptance standards of ASHE Section VIII.
These standards are less stringent then those required by ASME Section III.
This is a deficiency.
4.
WBG guali ty Control Procedure No.
24 (QCP-24), At)achment 2 (Box In Clearance) requires that for systems under 200 F and piping sizes from 2-1/2" to 12" the maximum allowed clearance between support and pipe, when suraned on both sides, be 1/8 inch.
gCP-24, Attachment 6 (Stop Clearance) specifies that the sum of clearances between both pipe stop attachments and the support structure be a maximum of 1/8 inch.
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 WBG Engineering and inspected and accepted by gC on triarch 22, 1979.
(b)
The summed clearance between the upper pipe stops and the support structure was 7/32" for support No.
RCC-457'he as-built drawing had been prepared by WBG Engineering and the support inspected and accepted by gC on December 7,
1979.
This is an infraction.
5.
WBG Project Directive No. 75, paragraph 6.3.1 states that "Calculations required for minor re-design shall be limited to:
those cases involving any changes in the sizes of members, welds or configuration, which will result in increasing the stress in members or connections..."
WBG Project Directive No. 75, paragraph 7.1.3 also states, in part, "All modifications...shall be noted on the support detai 1 to reflect field revised conditions prior to performing the work and initialed and dated by the Field Engineer or WBG Design Supv."
Contrary to the above requirements:
(a)
The "as-built" drawing for support HSLC-21 modified the originally approved detai 1 in such a way that the originally specified 1/4" fillet, all around, for attaching PC 2 to PC 4, was changed to a 1/4" fillet only on the outside of each PC 2 flange and a full slot weld attaching the web of PC 2 to the flange of
PC 4.
The deletion of the fillet weld on the inside of the flanges of PC2 would increase the stress in the connection
~
Calculations had not been prepared to justify the change and the changed welding details were not initiated or dated.
(b)
The as-built drawing for support RHR-326 was revised to specify a
new weld joint without the necessary calculations to justify the change.
The weld attaching the Lubrite assembly to the pipe was originally specified as a bevel-groove weld.
On Hay 16, 1980, the weld symbol was modified by WBG Engineering to indicate a square butt (groove) weld since the weld configuration did not conform to a bevel-groove weld.
The existing weld is not a groove weld configuration but is configured as a "cap" weld.
The as-built drawing had been prepared by WBG Field Engineering on flay 8, 1980 and the support inspected and accepted by gC on Hay 9, 1980, with a note that the snubber was missing.
The EgA audit identified that this weld was undersize and not welded to detail.
The EgA finding was, resolved by the notation that the weld symbol was changed and the weld was "OK" on Hay 16, 1980.
No calculations were performed justifying the adequacy of the resolution provided for the EgA finding.
(c)'he weld details of the as-built drawings dated June 8, 1979
. for support No.
RRC-3 were modified to conform to the as-built configuration on January 24, 1980 by a WBG engi neer.
This changed the welding detail from that approved by Burns and Roe in the original drawing on Harch 11, 1978.
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's approval were not provided to support the acceptability of this design change.
This is an infraction.
6.
Contract specification 2808-215, Section 17A, paragraph 3.4 requires that weld filler material for welding P-8 material shall be "type E308 or type E316 or as specified in the approved weld procedure".
The WBG Welding Procedure Specification k5 (for P-8 material welding) requires E308-16 filler metal.
Contrary to the above, on October 11, 1979 and thereabout, WBG personnel welded eighteen P-8 to P-8 material socket welds with the incorrect filler metal and with the incorrect welding procedure.
Welds numbered HS-538-1-FW2 through HS-555-1FW2 were completed using E309-16 filler metal using welding procedure specification b'6, (for P-8 to P-1 welding).
These are welds of thermowells to nozzles on safety relief valve lines.
This is an infraction.
7.
The WBG Work Procedure No.
WP-84, 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 magneti c particle tested as a minimum...at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more after completion and cooldown of the last weld in the sequence.
~."
Contrary to the above requirement, as of June 10,
- 1980, accepted welds 5-1 and 6-1 attaching pipe support EDR-392 to the sacrificial shield wall had not been magnetic particle tested.
The pertinent blocks on Form 'NF-6B for documenting the required inspections had been marked "NR" (not required).
This is an infraction.
10 CFR 50, Appendix B, Criterion VI, and Appendix D, paragraph D.3 of the PSAR state in par t "Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization."
With respect to the control of traceability of certified materials, the WBG procedures QCP-24 (paragraph 6.5), Project Directive No.
75 (paragraph 7.8.1) 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 prior to the cut."
These procedures were approved for fabrication by Burns and Roe on the dates indicated:
Project Directive No.
75 (Hanger Engineering Standard),
Revision 4, on June 26, 1979; Quality Control Procedure No.
17 (Traceabili ty Procedure),
Revision 8,
on April 4, 1979; and Quality Control Procedure No.
24 (Hanger Inspection-Traceable Systems),
Revision 8, on April ll, 1980.
Contrary to the above requirements, on January 18, 1980 the WBG QA Manager issued an interoffice memo (No.
PWS-102) to all QA/QC personnel, without prior Burns and Roe approval, which modified the traceability marking requirements of the above procedures in that the memo eliminated the requirement to provide a traceability mark on the material.
This is an infraction.
10 CFR 50, Appendix B, Criterion XVII, states in part, 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...Records
'shall be identifiable and retrievable."
The WPPSS implementing commitment for 10 CFR 50, Appendix B, criterion XVII, is described in Appendix D, paragraph D.3.4.17 of the PSAR which'tates that req'uired records shall be identifiable and retrievable.
Contract specification 2808-15, Part 52A Section
- 3. 17 requires the contractor to implement a system of receipt control which shall include a records check list designating the required quality assurance records structured to permit a current and accurate assessment of the status of quality assurance records during the 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 checked for completeness and acceptability...a document checklist shall be prepared..."
Contrary to the above:
a.
On June 23, 1980 a document checklist was not prepared nor was another method established for performance of an accurate and current assessment of the status of weld repair records for structural steel at elevation 524-feet of the reactor containment building.
Document reviewers could not assess from the records whether or not they had all of the weld records for repairs of steel shown on drawings FSK-215 through FSK-217.
b.
On December 28,
- 1979, the contractor certified as complete the records package for structural steel at elevation 565-feet of the reactor building, although neither a checklist or other method had yet been established for assessing the status of the records.
This is a deficiency.
2.
Contract specification 2808-215, Section 52A, paragraph 3.8 requires that "Objective evidence shall be available which substantiates the approval of a vendor as an acceptable source of equipment, material or services."
The contractor's Quality Assurance Manual,Section II, requires in paragraph 3.2.
1 "All purchases are made from either A or B vendors on the Approved Vendor's List" and in paragraph 3.2.4 "A file shall be maintained on each vendor, including the original basis for acceptance, and periodic reports of service experience."
Contrary to the above requirements, on September 11, 1978 the Bovee 5 Crail/GERI QA Department issued a letter to Puget Sound Company identifying that the vendor was "supplying ASME material to us in violation of ASME Section III, paragraph NA 3732."
No periodic report of the service experience nor other vendor survey report was in the vendor file, and no other data were available to identify the nature of the violations, their evaluation, and disposition of the material.
This is a deficiency.
3.
HBG Quality Assurance Manual, Section 10, paragraph
- 10. 3. 1 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."
ASME Section III, paragraphs NX-4321(b) and NX-4231.2 require the welders of temporary attachments and tack welds to be qualified and that the material used for temporary attachements be compatible for welding to the component material and be certified.
WBG Work Procedure 42, paragraph 20 requires, with respect to "Welder' Record",
a record of welder's name(s), filler metal used (includes heat and lot numbers as applicable),
and the date(s) that welding was performed.
Contrary to the above requirements, the weld record packages did not contain identification of welders or fillermaterials used for tack welds and temporary attachments made on pipe spools LPCS-756-5.7, LPCS-756-19.21 and LPCS-2271-1.
This is an infraction.