ML17275A694
| ML17275A694 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/06/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17275A692 | List: |
| References | |
| EA-80-020, EA-80-20, NUDOCS 8011170258 | |
| Download: ML17275A694 (7) | |
Text
APPENDIX A AMENDED NOTICE OF VIOLATION Docket No. 50-397 (Construction Permit No.
CPPR-93)
EA"80-20 Based on the results of an NRC investigation conducted between November 27, 1979 and February 28, 1980, it appear s that certain of your activities were not conducted in.full compliance with NRC regulations and the conditions of your Construction Permit No.
CPPR-93.
On June 17, 1980, a Notice of Violation (Appendix A) and a Notice of Proposed Imposition of Civil Penalties (Appendix B) were served'pon you, identifying the noncompliance items and requiring you to respond.
On July 11, 1980 and August 12, 1980, you responded to these Notices.
Upon consideration of your responses, items I.A, I.B.1, I.C.l, and II.A.lof the Notice of Violation are amended as indicated below:
I.
Items of Noncompliance Relating to the Sacrificial Shield Wall 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 criteria for determining that important activities have been satisfactorily accomplished."
Paragraph D.2.5.5 of the gA Program states that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances ahd shall be accomplished in accordance with these instructions, procedures or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative criteria for determining that important activities have been satisfactorily accomplished.
The activity may be prescribed in job specifications, work instruc-
- tions, shop coristruction drawings, job tickets, planning sheets, operating or procedure manuals, test procedures, or any other type of written form, provided that the activity is adequately described.
guantitative criteria, such as dimensions, tolerances, and operating limits, and qualitative criteria, such as comparative workmanship
- samples, shall be specified, as appropriate, for determining satisfac-tory work performance and quality compliance."
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 SSW by welding columns to inner and outer column splice plates and slot welding bottom segment ring beam to top of box. ring beam..."
Appendix A
- 2 "
Contrary to the above requirements, on June 14, 1978, assembly of the sacrificial shield wall in the reactor building was completed without the prescribed slot welds joining the upper sacrificial shield wall bottom segment ring beam to the top of the lower sacrificial shield wall box ring beam.
This 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).
B.
10 CFR 50, Appendix B, Criterion IX states "Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing are controlled and accomp-lished by qualified personnel using qualified procedures..."
Paragraph 2.8.9 of the gA Program requires that contractor pro-cedures for the ultrasonic inspection process be submitted for review and approval by Burns 8
Roe, the engineer, and review by
- MPPSS, the owner.
1.
The fabrication, erection, and testing of the sacrificial shield is prescribed in part by WPPSS Contract Specification No. 2808-215.
Appendix D of this specification, entitled "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 Box.Column Meld Maps 29B 29A M45 W21 W22 M22 Electro-Sl ag
. X-100 X"102 Weld Joint Joints 23, 24 Joints 31, 32, 114C Joints 23, 24 Joints 21-28 Joints 1-8 Joints 9-10 Joints 1-6, 8-10,
- 12. 13 Joints 1-4, 6-8, 10, ll, 12, 13, 167 Joints 15, 16, 22 132, 140, 30, 168, 144, 32, 33, 35, 37, 166 Date June 17, 1976 June 16, 1976 July 24, 1976 June 2, 1976
I'
Appendix A The contractor's ultrasonic test procedure (guality Control Procedure 8.0, Rev. 0, "Ultrasonic Testing" ) was approved by the owner (owner's agent) on August 5, 1976.
This noncon-forming condition was not identified nor were the weld joints retested after an approved procedure was provided.
This is an Infraction (Civil Penalty - $3,000).
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 estab-lished by qualified personnel using qualified procedures in acco'rdance with applicable
- codes, standards, specifications, criteria and other special requirements."
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 require-ments of pertinent codes and standards.
For special processes not covered by existing codes or standards, or where item quality require" ments exceed the requirements of established codes or stan'dards, 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 AMS Structural Melding Code D.l. 1-1974.
1.
Paragraph 3.7.'2.4 of the Structural Melding 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.
- 5325, 5412, 6055, 6056, 6058 and 6059 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.
Appendix A Furthermore, the NRC inspectors found no evidence that instruc-tions or procedures had been developed and issued, as late as April 1977, to implement the above Structural Melding Code requirements.
This is an Infraction (Civil Penalty " $1,500.00).
II.
Items of Noncompliance Relating to Pipe Whip 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.
Test 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 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 require-ments of pertinent codes and standards.
For special processes not covered by existing codes or standards, or where item quality require-ments exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined.
'aragraph D.2.5.11 of the gA 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
o
Appendix A 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, prototy'pe qualification tests, proof tests prior to installa-tion, preoperational
- tests, and operational tests to'erify 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 procedures 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 condi-
- tions, and provisions for data acquisition.
Test results shall be documented
'and evaluated to assure that test requirements have been satisfied.
The fabrication of safety-related pipe whip restraints is prescribed in part by MPPSS Contract Specification No. 2808-90.
Division 5, Section 5A, "Technical Specifications for Pipe Mhip Restraints,"
Paragraph 3.8.2, of the contract specification states,'n 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 component PWS 6-1 on 9/3/76, on component PMS 27-17 on 9/20/76 and on component PMS 30-5 on 9/27/76.
The earliest evidence of even preliminary approval of Procedure 8.0 is'/29/80".
This nonconforming condition was not identified nor were the weld joints retested after an approved procedure was provided.
'All three procedures gCP 8.0, 8.2 and 8.4 are required to satisfy Paragraph D.2.5.11 of the gA Program.
This is an Infraction (Civil Penalty
$3,000.00)
This Notice of Violation is sent pursuant to the provisions of Section 2.201 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
The Mashington Public Power Supply System is hereby required to submit to this office within twenty-five days of the date 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 on noncompliance; and (5) the date when full compliance will be achieved.