ML17277B260

Requests Response to Questions Re Apparently Improper Release of Draft Documents to Applicant by NRC Inspector. Documentation on Qa,Qc,Design Deficiencies & Mgt Problems Also Requested

ML17277B260
Person / Time
Site:	Columbia
Issue date:	09/28/1983
From:	Judith Weaver HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML17277B259	List: ML17277B258 ML17277B260
References
NUDOCS 8401190497
Download: ML17277B260 (65)

Text

NPIETY.EIGHTH CONGRESS MORRIS K. UDALL,ARIL. CHAIRMAN STANI.EY SCOVILLE STAFF DIRECTOR AND COUNSEL PIBLUP BURTON. CAUF.

ABRAHAMKA?EIL JR

TEX, N F. SEIBERUNG, OHe TONIO BORJA WON PAT. GUAM ES WEAVER, OREG.

ES J. FLORIO. NJ.

UP R, SHARP, IND.

OWARD J, MARKEY,MASS.

SALTASAR CORRADA. P.R.

AUSTIN J. MURPHY, PA.

NICK JOE RAHALLR, W. VA BRUCE F. VENTO, MINN.

JERRY HUCKABY.LA.

JERRY M. PATTERSON, CAUS RAY KOGOVSEK, COIP.

DALE E. KILDEE, MICH.

TONY COELHO. CAUF.

BEVERLY B, BYRON, MO.

RON DE LUGO, V.I.

SAMUEL GEJDEN SON. CONN.

WIUJAMPATMAN. TEX.

PETER H. KOSTMAYER, PA JAMES MOODY. WIS.

ALANL MOLLOHAN.W. VA JAMES McCLURE CLARKE, N.C JAMES F. McNULTY.JR AIKL RCHARD H. LEHMAN.CAUF.

MANUELUllAN.JR N. MEX.

DON YOUNG. ALASKA ROBERT J. IAGOMARSWO, CAUF.

DAN MARROTT, UTAH RON MARLEHH, MONT.

RCHARD B. CHENEY, WYO.

CHARLES PASHAYAN.JRCAUF.

IARRY CRAIG. IDAHO HANKBROWN. COLO.

DENNY SMITH. OREG.

JAMES V. HANSEN, UTAH

'BILL EMERSON. MO.

JDHN MccADLARC.

BARBARAVUCANOVICILNEV, COMMITTEE ON INTERIOR AND INSULAR AFFAIRS U.S. HOUSE OF REPRESENTATIVES WASHINGTON, D.C. 20515 September 28, 1983 ROY JONES ASSOQATE STAFF DIRECTOR LEE MC ELVAIN GENERAL COUNSEL TIMOTHYW. GUDDEN REPUBLICAN COUNSEL Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C.

20555

Dear Mr. Chairman:

The Bonneville Power Administration (BPA) has 'already paid over

$ 1.5 billion in interest on debt issued to finance Nuclear Projects Nos.

1, 2, and 3 of the Washington Public Power Supply System (WPPSS) and is apparently responsible for paying all costs associated with WPPSS 1 and 2, and 70% of WPPSS 3, whether or not these plants are ever capable of operating within NRC safety requirements.

As Chairman of the Subcommittee on Mining, Forest Management, and BPA, I am vitally interested in what BPA has bought for all these billions of dollars.

Following recent congressional hearings on NRC investigation practices, my staff reviewed the report of the Office of Inspector and Auditor (OIA) concerning the April 1982 release of a draft inspection report'o WPPSS by a Region V inspector, Paul Narbut. This OIA report, dated June 15, 1982, primarily addressed events at WPPSS 1

and 4.

But the records of the investigation also show possible improper 'onduct by the NRC inspectors assigned to WPPSS 2.

Specifically, the OIA report (at pages 19, 40 E

54) reveals

that, on at least one occasion, NRC inspectors shared with WPPSS a draft document listing over 200 'potential problems at WPPSS 2.

It is unclear from the OIA report whether some or all of these problems were discussed or resolved in any subsequent official inspection report or whether the NRC has investigated this apparently improper release of draft documents to the licensee.

I now ask NRC to provide the following further informa'tion on these events concerning WPPSS 2:

1.

What were the potential problems or safety concerns contained in the draft documents shown to the WPPSS 2

personnel?

Please provide the Subcommittee with all 800ii90497 83i22i PDR CONNB NRCC

'ORRESPONDENCEPDR

Nunzio Palladino page 2

draft documents shared with WPPSS as well as a summary and explanation of the potential problems and their significance.

2.

How were these potential problems subsequently handled?

Has any discussion of these problems appeared in official, public NRC documents?

Please indicate how each potential problem in the draft documents has been resolved.

3.

Have OIA staff or other NRC personnel ever recommended or undertaken any investigation of the possible impropriety of the inspectors'onduct in releasing draft documents to WPPSS 2 personnel?

If so, what were the results of the investigation?

If not, why not?

I would like a written response to these questions as soon as

possible, along with all

reports, studies, correspondence, memoranda or.other documents pertinent to these events.

Please also provide a list of all documents, including internal staff p

d d, ~1',

q 1'C 1,

design deficiencies, or management problems at WPlrSS 2 which were wry.tten by, sent to, or routed through NRC since 1980.

This list need not include documents contained in the public records of NRC proceedings.

With WPPSS 2

now in its "start up and operation" phase, it is important that the people of the Northwest can be assured that the plant has been designed and constructed in accordance with NRC requirements and that public scrutiny of potential problems has not been thwarted by improper conduct of NRC employees.

Thank you for your assistance.

Sincere M WEAVER, Chairman ub mmittee on Mining, Forest Mana ement, and the Bonneville Powe Administration

UESTION 1:

RESPONSES TO UESTIONS What were the potential problems or safety concerns contained in the draft documents shown to the WPPSS 2 personnel?

Please provide the Subcommittee with all draft documents shared with WPPSS as well as a

summary and explanation of the potential problems and their significance.

RESPONSE

The findings of NRC's investigation into the allegations and concerns obtained during this investigation were such that they represented a significant failure on the part of WPPSS to comply with NRC requirements; principally in the areas of the management of construction activities by their contractor(s),

adherence to written procedures and the implementation of quality documentation programs.

The findings were similar in many instances to previous findings of NRC's inspections at the WNP-2 project, which led, on June 17,

1980, to the imposition of civil penalties and the requirement that WPPSS submit information to NRC on the steps they would take to provide assurance of the quality of structures, c'omponents and systems constructed by their contractors.

The documents provided to WPPSS are provided in Attachments 1

and 2.

0

QUESTION 2:

How were these potential problems subsequently handled?

Has 'any discussion of these problems appeared in official, public NRC 'documents?

Please indicate how each potential problem in the draft documents has been resolved.

RESPONSE'he nature and safety significance of the potential problems were such that they confirmed the need for the harsh enforcement action taken by.NRC on June 17, 1980.

As discussed in our letter to you of July 13, 1983, this action by the NRC resulted in the suspension by WPPSS of essentially all construction activities at the WNP-2 site for several months.

The

WPPSS, in response to these enforcement actions, initiated comprehensive programs to upgrade the construction and quality assurance programs of site contractors to allow, after Region V review of the upgraded

programs, the restart of construction activities.

'The WPPSS also initiated a Quality Verification Program to verify the quality of construction completed prior to June 1980.

The findings of our investigation in June-July 1980 also served as the.basis of a Notice of Violation issued to WPPSS by the Director of NRC's Region Y office on August 15,

1980, a

copy of which, along with our Investigation

Report, is Attachment 3.

In accordance with NRC policy, these documents were placed in NRC's Public Document Room.

As mentioned previously, many of the concerns developed during the course of this investigation were similar to previous NRC inspection findings which led to the enforcement actions described in June 1980.

Recognizing the commitment by WPPSS to undertake a major Quality Verification Program to verify the quality of all safety-related construction completed prior to June

1980, a decision was made by Region V to

defer, in the interest of efficient utilization of inspection resources, the resolution of many of the specific problems and concerns to the Quality Verification Program.

Several of the problems or potential p

WPPSS management by the Region V Secti should specifically pursue to resoluti response to those items cited in the N

August 15, 1980.

These items are indi (totaling 40) on the typed listing of 4.

Our Region V office is continuing resolution.

roblems were identified to on Chief as matters WPPSS on, apart from their otice of Violation issued on cated by circled items concerns which is Attachment to follow these items to I

3 UEST ION 3:

Have OIA staff or other NRC personnel ever recommended or undertaken any investigation of the possible impropriety of the inspectors'onduct in releasing draft documents to WPPSS 2 personnel?

If so, what were the results of the investigation?

If not, why not?

RESPONSE

Neither the OIA staff nor other NRC personnel recommended or conducted any investigation into the possible impropriety of the Region V Section Chief's conduct in releasing the longhand written document described above to WNP-2 personnel.

This is because, at the time of this incident, the current procedures for distinguishing between investigations and inspections were not in effect.

Thus we do not feel that a separate investigation into the 1980 incident would be justified.

RE UEST'lease also provide a list of all documents, including internal staff reports and memoranda, on quality assurance, quality control, design deficiencies or management problems at WPPSS 2 which were written by, sent to or routed through NRC since 1980.

This list need not include do'cuments contained in the public records of NRC proceedings.

RESPONSE

We are uncertain as to the specific types of documents for which you desire a listing.

There are basically three categories of documents of the type you describe.

The first category includes correspondence between the NRC staff and WPPSS on technical matters relating to the license application and safety analysis report; reports from WPPSS relating to significant construction or design deficiencies; NRC staff safety evaluation reports; NRC inspection/investigation reports and related enforcement correspondence; NRC Bulletins, Circulars, Information Notices and Generic Letters; and NRC reports on the Systematic Assessment of Licensee Performance.

Final reports and correspondence relating to the WPPSS Design Reverification and guality Verification Programs also are included in this category.

Although there is no NRC public hearing on the operating license for WNP-2, documents in this category are routinely placed in NRC's Public Document Room.

A second category of documents includes the detailed

design, construction, quality assurance and quality control procedures, records and reports which NRC.inspectors examine in the process of inspections and investigations.

Detailed reports relating to the individual contractors and vendors covered by the guality Verification Program are included in this category.

Large numbers of reports and other documents in this category are routinely provided by WPPSS to the NRC Resident Inspectors at the WNP-2 s,ite.

Generally, d'ocuments in this category are provided to and retained by NRC inspectors for a period of time to facilitate our inspection or investigation activities, and returned to WPPSS or destroyed after they have served this purpose.

These documents are not placed in NRC's Public Document Room.

A third category of documents includes internal NRC memoranda containing recommendations, requests or information between or within program or staff offices.

Recommended enforcement and related correspondence between NRC regional and headquarters offices would be included in this category as well as requests for technical assistance.

A listing of documents in the latter category is included as attachment 5.

This listing was compiled essentially from the Region Y WNP-2 correspondence log with limited input from other HRC program offices.

A compilation of all documents in the first category would involve substantial staff effort, and it would be virtually impossible to compile a listing of all documents in the second category.

We would be pleased to work with your staff in an effort to identify specific types of documents from these categories which you desire.

Description of the Circumstances Surrounding Release of the Draft Investigation Results to WPPSS During the period June I - 25,

1980, an investigation was conducted by NRC's Region V office into allegations regarding construction activities at the WNP-2 site.

During the course of the investigation, interviews were conducted under oath with 34 project personnel from whom specific allegations/concerns were obtained.

Brief notations of these allegations/concerns were summarized in the form of a handwritten document by the Region V Section Chief in charge of the investigation.

This document served to formulate his daily action plan.

Notations were also made on this document reflecting the thoughts of the Sec-tion Chief as to how he or his investigation team might pursue certain allega-tions or concerns.

A copy of this document is Attachment l..

On June 20,

1980, with the approval of the regional management, a copy of this document was provided to WNP-2 management by the Region V Section Chief.

The longhand written document was subsequently typed by WNP-2 personnel.

A copy of the typed document is.

At the time the handwritten copy was provided to the WNP-2 manage-ment, the onsite investigation work was esentially complete.,

The purpose of pro-viding the document to the WNP-2 management was to facilitate communication of the safety concerns to the WPPSS management. for their prompt attention to them pending subsequent issuance of NRC s report on the investigation.

The report was issued on August 5, 1980.

According to Region V, no opportunity was afforded the WHP-2 management to change, correct, modify or otherwise influence the content of these documents.

The concerns included in.these documents were similar in many instances to those which had led to recent major. enforcement actions by the NRC.

(See response to guestion 2.)

Until recently the distinction between the procedures for inspections and those for investigations had not been clarified and the handling of this investigation was influenced by this fact.

The NRC has since moved to clarify these issues for staff and codify our investigative procedures.

In addition, a new policy regarding distribution of draft inspection reports has been issued to the staff.

Under this new policy, Region V's preliminary investigative results would not have been shared with the licensee unless it was necessary to obtain prompt licensee evaluation and corrective action as appropriate related to safety or security concerns.

ATTACHMENTS Hand written document - Summary of Concerns dated 6/3/80 Typed document o'f Attachment 1

Letter to WPPSS from R. H.Engelken, dated 8/15/80 w/enclosed Notice ofVViolation 5 Investigation Report Potential problems or problems identified to WPPSS management by Region V Section Chief Listing of Internal Memoranda/Documents

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SUMMARY

OF CONCERNS i.

2.

3.

Loss of Materi al Tracea bi 1 it a.

0 1 - IR cancelled - which reveals loss of trace.'

b.

8 208 - memo - (received by NRC - OK) c.

y i

Material Not Cancelled a.

Pipe in quarantined (2" Schedule

80) area with no reason why its there used to be 8000'f pipe in this area, now 2400'f pip, here,ore 5600'of pipe was install d.

b.

8U13152 pipe in guard area with no doc.

as to why its there - disc.

8 l.

Construction Controls OA Project manager brow beats the gA manager Cleanliness a.

Pipe in laydown area for 4 years - installed without cleaning.

b.

'12 ft. ladder in vertical run of 36" main steam line in containment (in gC II pipe in TG Bldg.)

c.

No system flush is planned before hydro - there is all kinds of garbage in lines.

d.

8 206 <<nameplate trapped in drain 1'ine.

5.

Laminations cracks in Pi es - Not Followed U

Pr'o eP COMPLETED S.W. underground piping, wrapped, gA mgr.

wou dn't ai ow proper follow-up.

Doc.

8 100 ex of.problem - slow laminations - gives accept. criteria as ASME VIII vice III.

6.

S.W. Under round Pi in Traveller shows that engineer walked down the system-cou n t have one this since -its underground.

7. I~d-II k

p p

p b

p p i i" 1

k h.

8.

Documents NF-6, NF-69

- Have information changed without explanation or initials/

ates.

103, 0

, 104, 203, (many more) 9.

Inconsistent Datin of Date Rod/Rin Issued and Datd Weld Performed - IRs issued in many cases 0

01, 1 2, 104 - 12, 0, 207, 10.

No Welder I.D. on NF 8 205, 207 Records Falsified (6000+ records we xeroxed) - Compared copied records with 12.

More Rod Turned in Than Issued/only are 16 of rod used.

8109, 8 103 13.

No Records for Each Da Weldin Was Done - 8110 + others 14.

Ins ectors Stam Issued 6/78 Next To Item Dated 5/6/76 - 8 112

A Mana er Did Awa w

E e

Exams for 8/79 Until 3 Weeks A o -

New hires aven't had eye

exam, AgE doing we d inspection haven t had eye exams.

Heat No.

HA0001 Used When Traceabilit is Lost-Its a fake number (no specifics w ere used ATTACHMENT 2

17.

Pi in Bou ht From Una roved Vendors in 1978 -

(No specifics)

Welder J. Hull Welded 8-18" Melds in the Same Meek - This type item should be investigated.

19.

3 4" Pi e of Certain Ht.

8 Was Bent 5 Ht, P Chan ed - This Was Then Cut Out 20.

and Re aced With New Pi e with No Heat No.

and no GC Witness - 8 129 MBG Field Su erintendent. Hill Do Mron Until Cau ht J. Wilkerson

- (no specifics)

Zl.

IRs Are Not Pro erl Handled - Some Are Not Issued and No One Follows Uo On Prob eo -;" 12, 201, 2, 20, e

1 shou d audit contents of IRs 22.

Class I Fitting Not Traceable - Not Pro erl Followed U

- 8 128 (floor drain) 23.

Arc Strikes On Piping a Problem - (no specifics) 24.

25.

Vendor Pi in(

Im ro erl Modified -

NPP1 Form used to doc.

changes to N-stamp piping no specifics 20 Packa e

Com letion Lists Have Disa eared From Packa es - (no specifics)

~O 26.

No Compaction Reports on Buried SW Pi in

- (no specific number) 27.

In 1978 MBG Took Packa es Out of the vault So the NRC Wouldn't See Them.

In March 1980 WBG Removed Material From La Down Area So the State Re s Mouldn't

~Shan 29.

Pi e Welded U

in Field With Plastic Ca Left on at Joint.

(no specifics) 30.

Ma 'or Problems with Missin Incom lete Documentation Packa es - See matrix 31.

Overl Com lex Procedures with Numerous Chan es, - WP-140 rev. 1,2;gCP-25, 10, doc. titled "Traceable Piping Document Routed" 32.

WBG Procedures Don'0 Reflect S ecification Reouirements In The Area of Removin Attachments -

5 200 memo of 5j18/80 33.

34 Ins ector Trainin is Inade uate - Only Read (or have read to them) the proce-

dures, don t fee this is enough.

No AI Si n Off of Final Records NF<<6A Form

- 8 202 35.

AI Initials Are Different ma be for ed

- Initial "G" on 8 213, others 36.

LPCS-63 Han er Packa e Lost - Don't know how resolved.

37.

Local 598 Has a Listin of Problems of WNP-2 Which Needs Follow U.

Overtorauein

- Tor ue Wrenches Should be 2 Tol.

No. 2-1 On Site.

All tor uin Done With 4 Tol or 10 Tol Tor ue Mr ench.

Contract 215 Class 2,

ASME III material (pipe and steel) has not been received with Charpy Test as required by the contract specifications.

40.

42.

43 44.

Fischer-Porter flowmeters (rotometers) in ASHE systems have been designed by a company that does not have an N-stamp (Ffscher-Porter) contrary to ASHE III Requirements (Document P~ 305)

Serious minimum pipe wall problems exist:

a.

Counterbores made too deeply (See mern 0 304) b.

Burns E

Roe didn't speci,y enough wall.

The AI ran one calc.

showing that HS pipe did not have enough wall.

B/R reduced corrosion allowance from 1/8" to

.090 for these specific pipes only.

(See PED 215-H1747),

B/R allows additions 12$

reduction in wall for surface blemishes.

B/R has not checked other pipes for similar problem.

(See document P 303)

MBG buying piping to ASHE 1977 Edition w/o certifying that it meets requirements o.

1971 Edition H73 Add. as required in Section 15( "Pipe Supports" for Contract 215.

E ui Pads 5 Concrete Floor - Records are insufficient to determine whether or not rebar is there.

Curing records not consistently kept and those kept may be unsatisfactory.

(Documents 0 400, 401, 402).

RFI procedure used on site is not the one called for in spec.

RFI form is different.

45.

Contract spec.

required TSP in piping system, but a letter from Burns 5

Roe to MBG deletes requirement.

Dodds

~

~

~

~

Laminations fn structural steel in steam tunnel - Being handled.

Pybus steel vendor insp.

by Richard Laughton 5 Rorg.insp.

Arc strikes away from weld on hangers not required to repair.

OK on structural steel.

Desk broken into 8 records relating to material traceabilfty were taken.

No evidence of forceful entry.

0$.

3.

Look into question of HIC on storage racks could provide mtrl. traceability.

Not designed for traceability.

NPS hangers stamped with large Numbers Construction convenience steel used and stamped with heat nos.

pr ovided by NPS.

Check 78-79 time period.

Two letter id.

General For eman.pa&>

Initfal installation (i.e., prior to 1977) for about 1 year did not have procedures for installation of hangers.

Requirements not in place.

Construction convenience steel bulk ordered used on all proj?

How controlled?

or fence being tom down.

Found double numbers on hangers.

Used wrong numbers.

gExamfned 15 hangers no double 8s.

'nd prep of pipe - Clean with emery cloth only - don't proceed to bright metal.

Worried about min. wall.

8.

Condensate pipe used several welders.

Only one welder of record (ie. final passes.

Check materials at 548'levation.

yd-ID angle iron on pallet in Class 1 storage w/o heat nos.

1.

Ed Harrington/Pete Garcia/Roy Clause - Taped session on inspector i.d. issues-what's wrong on the project..

I.d. of items in contract spec.

not included in proj. requirements/procedures.

.~ ~gmt.<Interim - matrix check with PSAR/FSAR commitment.

3.

.4.

6.

8.

9.

Arc strikes on hangers

<< Proc.

okays - contrary o spec.

Anchor plates - Melding split anchor housing - did some welding.

PMS 102 r fer ence on document where trac ability is in qu stion on hangers.

Hinimum wall on socket welds may have been taken.

Sampled, found 15>> below min. wall.

Cut out and replaced.

Did no inspect additional sampling.

Lot of junk left in pipe.

Files of Lloyd Norris, Level III, NDE indicates ET rejection of welds because of junk in area of interest.

16 shots.

Drains in plant plugged with debris -

Q on flush out tests?

Care of Valves during welding, weld repairs.

2 repairs then cut out so doesn' require engineer approval.

10.

Yalves may not be environmentally qualified for reduction service.

.11.

Hain steam may be below minimum wall.

13.

v 14.

Stop on Hain Stm.

Stop (west side) located such that valve may overdrive, ram against ceiling/flow and cause damage to system.

D Circumstances related to 'Gilbert-Commonwealth check and certification of lo/hi drains and vents.

Ba'nstalling seal'I bore pipe to toi ra~aces t 6" on iso where spec.

is

+2 -0 on iso (could be +6>>0 ic ard Layton i.d. problem).

15.

QA audit procedure - limited scope operation - no muscle.

M6.

17.

18.

19.

QA Manual requires QA Manager to examine IRs for trend evaluation monthly per ASME Survey "N" Stamp (Not done)

Dwg.

RHR 897 - 2027, FM 13, azimuth 315

, elevation 552'.

Reactor vessel nozzle to feedwater saw drop ~ through/Reshot OK should be rejected.

Still checking out.

MPPSS may be checking.

a Question on availability of procedures for QA insp.

Copies all removed from field except for one copy.

(Not quite true -

o others outside RB in trailers)

As-built done from desk rather than walk down.

Hain air intake into control room.

Flanges may not be properly insulated.

Resistor reading should be 1

H ~

- was 1 ohm.

Order of review of documentation is in question.

Engineering was supposed to do document review prior to as-builts.

Instead, does review after final QC sign off of as-builts review is done (may make changes QC unaware of).

Engineering may back date documentation rather than follow SOP of entering review date and initial.

"Can go to most any documentation package and find errors 23.

Stor s records not given to Owrer for review.

24'.

25.

26.

27.

LPCS 8

HPCS.

HCR on pitting and indentations below minimum wall.

This should have been identified by associated pipe.

MPPSS has issued an NCR on pipe in LPCS but may not have done so on HPCS.

IR prepared by inspector.

How are IRs voided'?

Feedback to inspector.

Is justification provided to close the loop on outstanding EPs.

Helding deparbnent has many references to unconsumed inserts.

Contract requires RT of 10~ of each new welders work for each size of pipe and position welded.

Hay not be following this requirement religiously, rather RTs for gC of the "good" welders.

1.

Inside CY. Cut out and replaced substantial quantity of pipe with wrong heat number due to a heat number mix up.

ustly 3/4" small bore pipe

~

2.

Use surplus pieces of material from another hanger.

'Transfer heat numbers.

Constant retrofit on hangers.

3.

Changes to proc dures are production oriented rather than QC oriented.

4..

Annual eye examinations ww e not given on schedule.

Cancelled by order of Sly from February Oil April/khy (exams due in February - done in April or Hay) 5.

Go not address are strikes on hangers ifrot on weld.

6.

Has one instance of wrong heat number on pipe hanger.

1.

QAP/QCIs are prepared by Ed Harrington (Construction rather than QA/QC).

2.

Training needs improvement.

Crafts need training (Several complaints in this area.).

Action Items 2.

3.

6.

7.

Get information on tM 975-4.6 8 elev.

501 - 4" SS APSE spool.

Should be reported as 50.55(e) item IR on 5 weld.

llo QI.

Acceptance of Power Piping Hangers to commercial weld standards.

(Examine several hangers to verify quality of welding.)

Reason for EQZ reduction from 100>> to 20>> sample of completed hangers con-sidering the high rejection rate, i.e.: approx.

80-90%.

ASME QAM: QCPs; MPs; Project Directive Contr act Specification.

MPPSS audit of hanger doc. pkgs. approx. I month ago.

Verify as-builts not charged to reflect oversized welds.

~~fa C~.

bus Utilization of inspect~.

2.

3.

5.

6.

QCP-24 revised to r emove requirement for hanger inspections to check for critical characteristics such as arc strikes, tracability, elongated holes, oversized welds, critical weld symbols, etc.

Oversize welds or cases where four sides of plate were welded instead of two deemed acceptable.

EQA (IVI) punch sheets removed from final documentation packages.

EQA (IVI) does not have own set of procedures.

Go to adjacent trailer to review procedures.

?

EQA (IVI) may not be functioning in accordance with QAM. (Get a copy of WBG's QAM)

Originally EQA did 100>> inspection of hangers (audit).

Had rejection rate of approx.

90>>.

Inspection requirements reduced to 205 random sample.

Rejection rate still about 90-95 Rejections are about 50>> documentation - 50" material deficiencies.

7.

8.

9.

10.

Records of reqork not being identified on detail drawings.

HPPSS audit of hanger documentation discovered items missing from packages (Store requisitions, etc.).

Stores requisitions missing on EQA review suddenly appear - question validity of stores requisitions.

(Green copies used to check in field, white goes in documentation packages.

Can't prove anything wrong-s us pi cious. )

Instructed to accept hangers as long as one of the numbers on store req.

or bill of material good. (Sly's memo on tracability.)

12.

(This item was completely illegible to type - scribbled through}

As-builts are not changed to reflec. oversized welds, only undersized welds.

These are dispositioned as acceptable by WBG engineering.

(?Should they be referred back to the designers for dispositioning, i.e.,

BAR engineering.)

13.

Structural steel inside CY contains beam pockets, undersized

welds,

~

.lack of fussion,

undercut, slag, porosity, arc strikes,.etc.

Also, excessive grinding in base metal.

14.

HT tests of welds of structural steel done cold rather preheat because slag pockets pop out.

Re NT will show. cracks.

15.

Documenting As a single weld rather than 2 welds.

Info for

'MPPSS 16.

17.

18.

19.

20.

21.

22

'3.

24.

Root pass inspec sons are missed but are being bought off in final documentation packages for structural steel.

Lot of inspection of sacrificial shield was recorded for wrong weld seams; i.e.; look from inside out rather than outside in on weld map.

A S

Forced to accept as being receiving inspected 2/4" floor drains supplied by Peter Kiwit (not on approved vendors list.

Should have been Owner-accepted

material, not HBG.

Designated Class I air intake structure drains for turbine building.

Drains installed 4/7/80.

Procedure 145 requires convenience steel to be painted yellow when placed in storage, i.e., not when removed.

People should be responsible for material ordered such as valves,

hangers, etc. - Haste of money.

'PPf5nt j c.c

+~r44e gC inspectors are buying hangers without a journeyman being present.

Classroom training is minimal and that given, instructors are not responsive to questions - accept what your told without question.

Do not return voided IRs to originator.

This fs requir'ed by the procedure.

gCP-24 acceptance criteria is different from specifications, i.e.,

allows appli..ation af 90 ft-lbs torque for 1/2-inch Hilties guick Bolts rather than 50 ft-lbs.

Action items IRs need copies/examples or" IRs that were voided w/o being entered into the system - or given a number.

w/?Dike Br'ckle.

2.

Copies of memos from engineer/QA that may override the procedure:

AT 3.

Flashlight in Reactor pressure vessel drain.

GE list~kg.

AT 5.

WNP 1/4 - valves may be in backward.

AT ~ 975-4.6 8 elevation 501' Modified 4" SS APSE spool.

IR on 5 welds showed lack of penetration.

Schedule pipe from vendor shops No action taken on rest of IIa,spools supplied by APSE.

(Possible generic prob.)

o S-I System ASME III, Class III - NSR decontamination solution line.

Engineer does

~not want to prove - other prolems.

Case of pipe in CV where anytime made attachment had a problem with cracks or laminations - repaired, no action or looked at rest of pipe.

Pipe inside CV, RClC 695 at 606'levation attaches to spare frame.

Long run to pipe could be below minimum wall by UT.

May have been dispositioned.

2-2 AT Had some BCG line TC, (55) on main steam line where purge gas was not established.

Posibility of sugaring.

INC - 18, SS to SS weld 304.

Did not establish purge.

MS-58-1 thru 775 1 (FW-2)

Memo to welding engineers (PS6 4289) ref.

P3, P4 5

PS materials allows lunch break or shift change as long as preheat maintained.

(Note:

No welding done since QC found out and disagreed with practice).?

Does this constitute change in procedure' 6.

Engineer says if pipe has heat number on storage racks and on isometrics (spool piece),

number doesn't need to be on pipe.

"Pup" pieces.

A&IE code pipe.

7.

RHR-667-8.12 HtL-24897 not stomped between welds SA-5C.

Painted on CS pipe.

Iirote up on DCL as needing to be scribbed on pipe.

Plerified by Kirsch.

Await dispositioning of PCL finding.

AA0001 on main steam 1'ine in T.G. for level indications, changed out 3.but left in one.

(Verified by Hernandez that this was a configuration change and condi-tion is satisfactory).

Conservation took valve apart without QC authorization or removal/assembly from discovered.

Hold tag put on valve since i't was misty inside.

(Still op.)

(T, 10.

Rejecting all power piping hangers.

At meeting included Monis, Nebster, Plalkins and Sly.

QC constructed to accept welds to commercial weld stm-dards.

(i.e., trailer hitch).

Sandblasted and given to painting contractor who refused to paint because welds defective.

Okay ins'de CV not outs.'de.

Practice has been in efrect fo 3 - 4 months.

Nhen get P.O.

or Power Piping hangers, Mac Haye writes in commercial standards.

PN 11.

Of a 20$ sample of hangers with documentation in valut, 80~~ were found to be unsatisfactory and needed to be returned to QC 'for correction.

()'PPSS initiated program).

12.

QC's book of heat numbers disapeared for 4 - 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> during a QC verification check of correct materials in the hange~.

Fab.

Shop.

PN 13.

0 office PN 14.

Meld workers on anchor support plates when bolts are in place.

? effect on anchor shafts.

(One case where anchor pulled out from wall).

Blanket NCRs on dispositioning of anchor bolt problems.

OWNER 15.

Procedures not readily available for review - holds job up.

Energy body feels the pressure.

Scaffolding and tube block wedge between a line and structure where large bore piping comes out of sacrificial shield wall at 551-4'levation.

Turbine Generator crane rail bolts were over torqued.

There an 1200 bolts of which 2/3 were torqued before problem was discovered by QC for sample of 60 bolts demonistrated all to be over torqued.

Resolution may be to replace the the 60 bolts rather than all bolts.

.Shims under hold down plates are suppose to be tight against rail.

Many are stuffed with flat stock to achieve this.

At 524'levation - Structural steel repair cannot determine from weld records when work was done.

Hold plates are missing bolts).

Records lack visibilityto type and size of repare and/or traccability,to filler metal or welder.

al No formers on-site testing of QC inspectors OVT with first line QC inspector 5 - 6 week.

2.

Dispositioning of IRs 49504 (2/6/80) - double heat no.

on same piece of pipe.

Orig. N-144-13 etched in pipe 5 painted over.

Ht No. J816356 scribed thru paint.

(J applicable to 2" sch.

80 not 2" sch 4-0). ~ control of scribe-tools.

Special authorization etc.

IR 4980, 2/12/80, No. number scribed on pipe - dispositioned to accept because traceability to Ht. No.

11-4-6 ) established thru w/p and vertical stress req.

"sice HT No.

N14403 on this pipe".

S.

Investigation of 2" sch.

80 pipe in quarenteen heat no.

124776 and 12477 on 616 thru 18 of 1980 disclose entire section with longitudiental discontinuity the entire length of pipe 433 around the length of pipe inspired motion (visual inspection by QC - questionalbe areas prior to installation).

NOT LEDGIBLE.

6.

7.

IR 4219 identif'es problem M'th NIX NDE ques ions dispositioning o

IR (dated 9/7 thru 9/14.

NCR-4898/IR-4287 - NCR Circumvented by PED-2018 - Work proceeded prior to NCR being dispositioned.

8.

Qualify of Engineering.

9.

Reaming of holes by crafts.

Not being checked by QC in all cases.

10.

Failure to recieve timely response from B/R on RFIs.

11.

330 ft of 6 X S X 14" tube steel mag.

found cracks during installation of 181 330 ft nnd 20 ft left in store

12.

13.

14.

15, 16.

17.

18.

19.

20.

21.

22.

23.

By procedure, field engineer is allowed to change design by red line drawings.

Specs require calcs in design change.

Cases where welder couldn't make weld.

Field eng reer "ives ok without forming cal;cs.

(Illegible - best guess on this one)

No review of field engineers

. design calcs.

(i.e., required by WBB program)

Can red line drawings no one looks at design calcs.

Hanger designs from BKR that violate design criteria/sepcifications.

Hany are not installable because BAR engineering does not look at total building layout - i.e., other lines/cable trays, etc.

Field Engineer then required to lay out to the best of his ability.

Eng.

~ma write FRI about: 6 mos. later, may get answer.

Therefore if you want to get the job done you red line the drawing if you can define as a "minor" design change (1977-1978 are rea1 problem years).

RIF-2760-RHR-R Hanger already installed per Rev. 0.

By Rev. I B&R changes hanger design.

Design fails deflection criteria and requires welding 50~ across width of existing steel to...........flange BSR response to field..................(Illegible)

(Illegible - best guess)

IE 400-RHR-12 (RFI) Field engineer stated pipe anchor release as revised by BAR on 12/10/79 has insufficient reinforcing still in west wall.

B8R response on I/21/80 stated hanger should be re-designed.

('By who and when).

BER design guides may not address pipe bearing stress.

Example provided in RFI generated 5/23/80 by KDC where actual was 165,000 psi and allowable was 37,500 psi.

Could be a prevalent problem.

WP117 was revised by WBG in January 1980 - Still have not received response or approval - are continuing to work to an outmoded procedure.

Hanger FOR 385 or 358 was underdesigned and had additional bearing plate

.installed in place in the field.

Waht effect does welding have on the concrete adjacent to the weld and...........(Illegible)

Illegible There is a lack of'esign control.

EgA may not be looking for backup calculations.

The qualification of field engineers performing "red line engineering" (minor design changes) should be questioned.

AE has given contractors ability to make design changes per PD-75 RG-3:lwithout design review/control.

Hanger LPCS-11 accepted by first line gC 8 Engineering.

Can make field.

changes but does not have to justify as long as change meets procedure.

Should require written tech'ustification and/or calcs.

24.

Problems ID by EgA are not being handled/dispositioned as nonconformances.

Being handled as just another item.

25.

(CP-2K - Max diameter cannot excee'd >1/8" bolt diameter.

COND 701 required extensive rework when field engineer requested bheck because gC had listed this item in NF 237 as not applicable.

Spec is being mis-

. interpreted by gC.

This could be a generic problem.

HPCS-23 is example of "gross" case.

Other EDR-133, LPCS-3 (..........40-50 weeks).

Cont. are reaming holes.

26.

AEs design organization and criteria needs to be examined.

27.

Out-of-plane stress on hangers is very weak - can conceivable over-stress welds.

(i.e.,

FPC-120, FDR-384, RCC-115, CAS-517 CB/R supplied fix following RFI).

CAS 514 (A/E may say its ok based on immediate calc)

Design Guide M400 - may not contain criteria for out-of-plane stress.

28.

NRC Bulletin 79-02.

No clear criteria in M400 for stiffening anchor plates nor is di rection being provided.

How is this requirement of Bulletin being satisfied.

29.

Criteria for off-center hanger base plates is lacking.

COND 442 question BAR on this subject..............BAR did not consider this to be a

critical dimension.

30.

Have not seen any visibilityof Owner or BAR in plant.

Not ever present during installation.

0 0