ML17276B107

Responds to NRC Re Violations Noted in IE Insp Rept 50-397/81-21.Corrective Actions:Qc Record Added to Provide Necessary Guidance for Determining When Liquid Penetrant Testing Required

ML17276B107
Person / Time
Site:	Columbia
Issue date:	01/20/1982
From:	Matlock R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML17276B106	List: IR 05000397/1981021 ML17276B107
References
GO2-82-87, NUDOCS 8203020414
Download: ML17276B107 (10)

Text

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Washington Public Power Supply System PO. Box966 3000GeorgeWaahingtonWay RichlandWaahingtor!S@ggy $09)3725000 Docket No. 50-397 S "':op January 20, 1982 G02-82-87

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I'iae Mr. B.

H. Faulkenberry Chief, Reactor Construction U.S. Nuclear Regulatory Commission Region V

1450 Maria Lane, Suite 210 Walnut Creek, California 94596

Reference:

NUCLEAR PROJECT NO.

2 NRC INSPECTION OF OCTOBER 1981 CONSTRUCTION PERMIT NO.

CPPR-93 Letter from B. H. Faulkenberry to R.

G. Matlock, dated December 21,

1981, NRC Inspection at WNP-2 Site - 1981 Report No. 50-397/81-21 The reference letter delineated the results of the October, 1981 inspection of activities authorized by NRC Construction Permit No.

CPPR-93.

Further, the reference identified certain activities which were not conducted in full compliance with PSAR requirements set forth in the Notice of Violation enclosed as Appendix A.

This item of non-compliance has been categorized into a level as described in Supplement II of the Federal Register dated October 7,

1980 (45FR66754) as the Interim Enforcement Policy.

The specific finding, as identified, and the Supply System's response is provided herewith as Appendix A.

R.

. Mat oc WNP-2 Program Director RTJ/kd

Attachment:

Appendix A cc:

W. S. Chin, BPA - Site R. A. Feil, NRC Residnet Inspector, WNP-2 A. Forrest, Burns and Roe -

HAPO N.

D. Lewis, NRC J. Plunkett, NUS Corp.

R.

E. Snaith, Burns and Roe -

NY V. Stello, NRC EDC WNP-2 Files 8203020414 820223

(

PDR ADOCK 05000397 8-,

PDR Q

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STATE OF WASHINGTON)

)

COUNTY OF BENTON

)

DATED R.

G. Matlock, Being fi'rst duly sworn, deposes and says:

That he is the Program Director, WNP'-2, fog th'e WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the appl icant herein; that he i s authori zed to submi t 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.

C3 1982 R.

Mat 1 ock 1982 On this day personally appeared before me R.

G. Matlock 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 mentioned.

~h GIYEN under my hand and seal this ~

day of oary u icinan or te ae o

Washington Residing at

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APPENDIX A As a result of the inspection conducted during October

1981, and in accordance with the Interim Enforcement Policy, 45, FR 66754 (October 7, 1980), the following violation was identified:

10CFR50, Appendix B, Criterion V, 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..."

Section D.2.5.5 of the PSAR for the Washington Nuclear Project Unit No.

2 describes that measures would be established to comply with the above requirement.

Burns and Roe Engineering instruction to Bechtel, in specification change document PED-215-W-A804 required that piping walkdown inspection for arc strikes shall include participation by an AWS certified gC Inspector and a Field Welding Engineer.

It also required that upon inspection and evaluation by these individuals, any unacceptable defects shall be removed by grinding and the ground area be subject to liquid penetrant examination, in accordance with applicable Codes and Standards.

The applicable ASME Code Section III, Part 2500 includes varying requirements for liquid penetrant testing, depending upon the class (1, 2, or 3) and the product form (plate, casting, welded pipe, seamless pipe).

Contrary to the above requirements, on October 29, 1981 the following circumstances persisted:

FINDING A Bechtel guality Control Inspection Records (series P-1.10 walkdown inspections) for the period of August 1981 to October 1981 included no requirements for liquid penetrant testing, and showed that liquid penetrant testing had not been performed for arc strike inspection, evaluation, and removal for System 58.0 (Service Water System).

Neither the ()uality Control Inspector nor the Supervisor could identify the ASME requirements for liquid penetrant testing when they were first interviewed by the inspector.

This is a Severity 5 violation (Supplement II).,

SUPPLY SYSTEM RESPONSE A.

Corrective Ste s Taken And Results Achieved - A Bechtel ()uality ontro

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was generated for use as an attachment to the referenced

()uality Control Inspection Records (series P-1.10).

This supplementary record provided the necessary guidance for deter-mining when liquid penetrant testing was required, based on ASME class and type of material (i. e. forgings, tube and fittings welded with filler metal, cast products, and tube and fittings without filler metal).

Arc strike inspections previously performed were evaluated to this supplemental instruction and it was determined that previous inspections

had, in fact, been properly performed.

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Appendix A Page Two SU PLY SYSTEM RESPONSE (Continued)

B.

Corrective Ste s Which Wi 11 Be Taken To Avoid Further Items oncomp iance -

urns an oe ngineering instruction to "gi i

i 1i -A84) p seded on November 30 1981 by PED-215~M;8199.'.

This engineeri'ng direction more clearly defines the Nondestructive Examination requirements to be employed in the Welding Arc-Strike Removal Program.

This directive also now requires that "examination shall be performed by... personnel... that have been trained specifically in arc strike evaluation by the Engineer."

This training program is currently in progress and wi 11 provide instruction to Bechtel and other site contractor inspection personnel.

I, C.

Date Of Full Com liance - Form QCF-4000, Supplementary Arc ri e emova ecor

, was included as an attachment to the Quality Control Inspection Record for use with PED-215-W-A804 and applicable training to inspection personnel was completed November 11, 1981.

1 Subsequently', 'he engineering direction which formed the basis for the noncompliance, was superseded by PED-215-W-B199 on November 30, 1981.

A qualified Field Welding Engineer did not accompany the Bechtel QC Inspector during arc strike evaluations.

Quality records for the period August 1981 to October 1981 included no decision to grind and accept arc strikes.

Examples where arc strikes had existed can be found on piping shown by isometric drawing numbers SW(7)312-1, SW(17)300-1.3, SW(27)308-1.2, SW(29)298-1.3 and 4, 6, SW(80)091-6.13-..1, and SW(100)013-1.8.

This is a Severity Level Y violation, (Supplement II).

SUPPL'Y SYSTEM RESPONSE A.

Corrective Steps Taken And Results Achieved - Although a Field e

ing ngineer i

not accompany t e ec tel QC Inspector during initial arc strike evaluation, all unacceptable defects noted by the QC Inspector were documented on Bechtel Noncon-formance Reports and dispositions were provided by Field Welding Engineering after their evaluation of the defect.

In addition, a Field Welding Engineer was assigned to accompany the Bechtel QC Inspector during arc strike evaluations performed after the above deficiency was noted, as required by PED 215-W-A804.

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Appendix A Page Three SUPPLY SYSTEM RESPONSE (Continued)

A.

(Continued)

The referenced guality Control Inspection Records include as an attachment a "mark-up" of the applicable piping isometric drawing.

All arc strikes detected are noted on this drawing along with the inspectors comments regarding acceptability or required rework.

The ()uality Control Inspector performing the inspection was qualified in accordance with the engineering direction in effect at the time the deficiency was noted (i.e.

AWS gCI Certi-fied Welding Inspector).

B.

Corrective Ste s Which Wi 11 Be Taken To Avoid Further Items oncom t ance -

e note requirement contasne sn rogect nganeering irective 215-W-A804 was deleted by PED-215-W-B199 which was issued November 30, 1981.

C.

Date Of Full Com liance - Full compliance was achieved on cto er w en the deficiency was noted.

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