ML19338G511

Responds to NRC Re Violations Noted in IE Insp Repts 50-508/80-06 & 50-509/80-06.Corrective Actions: Contractor QC Directed to Document Rework in Accordance W/Applicable Project Procedures

ML19338G511
Person / Time
Site:	Satsop
Issue date:	09/26/1980
From:	Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19338G508	List: IR 05000508/1980006 ML19338G507 ML19338G511 ML19338G513 ML19338G514
References
GO3-80-2364, NUDOCS 8010310012
Download: ML19338G511 (4)

Text

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~s September 26, 1980 G03-80-2364 fluclear Regulatory Commission, Region V Suite 202, Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California 94596 Attention:

fir. G. S. Spencer Chief Reactor Construction and Engineering Support Branch

Subject:

WPPSS NUCLEAR PROJECTS 3 & 5 flRC INSPECTION OF WNP-3 AND WNP-5 DOCKET NUMBERS 50-508 AND 50-509

Reference:

1) Letter, G.S. Spencer to J.C. Lockhart, same subject date September 4, 1980.

2) Letter, D.F. Knuth to all AEC Licensees, " Criterion for Determining Enforcement Action and Categories of

!!oncompliance", dated December 13, 1974.

Dear f4r. Spencer:

This letter is in response to your letter of September 4,1980, which discussed the results of the inspection conducted June 25 to July 18, 1980, of activities authorized by Nuclear Regulatory Commission Construction Permit flumbers CPPR-154 and CPPR-155. The letter identified two items of noncompliance categorized in accordance with Reference 2 and required the Supply System to provide a response to these items.

The specific fluclear Regulatory Commission Findings, as stated in your letter, and the Supply System responses are provided in Attachment I to this letter.

Should you have any questions to desire further information, please feel free to contact me directly.

Very truly yours, ELM /2cdog;;

D.L. RENBERGER Assistant Director, Technology Attachment cc:

D. Smithpeter - BPA BC10310 O\\O Ebasco - New York WNP-3/5 Files - Richland b,gg

Attachment I Page 1 of 3 flVCLEAR REGULATORY C0!@11SS10ft - FIrlDIrlG A A.

10CFR50, Appendix B, Criterion XIV, states, in part, that

" Measures shall be established to indicate...the status of inspections and tests performed upon ind~ividual items of the nuclear power plant....These measures shall provide for the identification of items which have satisfactorily passed required inspections and tests, where necessary to preclude inadvertent bypassing of such inspections and tests...."

Paragraph 17.1.14 of the QA Program states, in part, that

"...the WPPSS Quality Assurance Program requires that Contractor's inspection, test and operating status procedures are written and submitted for review and comment by the AE.

These procedures shall establish measures which provide for:...b)" The identification of items which have passed required inspections and tests, where necessary to preclude inadvertent bypassing of such

. inspections and tests...."

Contrary to the above requirements, as of July 9,1980, the civil / structural contractor working under contract specification 3240-263 for structural steel erection at Units 3 and 5 had not established measures which identify items that nave satisfactorily passed required inspections and tests such that inspections and tests are not inadvertently bypassed.

The inspection of the bolted joint connecting structural beam flo. 278C to the Unit 3 auxiliary building west wall at the 362.5 ft. elevation was reported as inspected and accepted by the contractor's Quality Control personnel on January 4,1980 on the structural steel erection checklist, whereas in July 1980 it was found that the joint was improperly assembled and that the joint inspection had been inadvertently bypassed.

This is an infraction.

NUCLEAR REGULATORY CO:0!I5SION - FINDING B B.

10CFR50; Appendix B, Criterion V, states, in part, " Activities af fecting quali ty shall be... accomplished in accordance with...

instructions procedure, or drawings...

Paragraph 17.1.5 of the Quality Assurance Programs states, in part, that " Contractors and Vendors, including Ebasco and C-E, arc required to have written instructions procedure policies, and/or drawings which govern their quality related activities..."

Contract specification No. 3240-263 for structural steel erection requires that structural welding, a quality related activity, be accomplished in accordance with the AWS Structural Welding Code, D.1.1.

Paragraph 3.7 of this code states, in part, that "The removal of weld metal or portions of the base metal...shall be in such a manner that the remaining weld metal or base metal is not nicked or under cut... Unacceptable portions of the weld shall be removed without substantial removal of the base metal.

Additional weld metal to compensate for any deficiency in size shall be deposited..."

Attachment I Page 2 of 3 fluCLEAR REGULATORY COMMISSION - FINDIf;G B - COIITINUED B.

Contrary to the above requirements, as of July 9,1980, the civil /

structural contractor working under contract specification 3240-263 had installed structural beam No. 247 A at Unit 3 with a reinforcing plate weldment which contained a ground out area along the full le 7th of the weld toe of a size approximately 3/16" wide and up to 1/o" deep into the 3/4" plate.

Additional weld metal had not been added to compensate for the deficiency in size resulting from the grinding.

This weld had been inspected and accepted by the contractor's Quality Control Organization.

This is an infraction.

fiUCLEAR REGULATORY COMMISSION - ITEM A Corrective Steps Which Have Been Taken:

lionconformance Report number 3823 was prepared on July 11, 1980, to disposition the structural steel bolted connection identified by the Nuclear Regulatory Commission.

Nonconformance Report number 3823 was dispositioned as "other rework" which required the contractor to rework the connection to conform to design documents.

Contractor Quality Control was directed to document the rework in accordance with their applicable project procedures.

Verification of rework completion was made by Contractor Quality Control on September 2,1980, and accepted by the Supply System on September 4, 1980.

Corrective Steps Which Will Be Taken To Avoid Further Violation:

The Contractor initiated an Interim Procedure Change i;otice (IPCN) to Construction Procedure (CP) 05, Revision 2.

This IPCM requires as-built drawings of all Structural Steel connections.

In addition, each connection on the as-built drawing shall be verified as completed by the inspector.

The responsible Quality Control Inspector's acceptance of the physiqal connection will be indicated by marking on the structural members with a paint marker.

Training classes were given July 10, 1980 to responsible Quality Control Inspector's for familiarizaiton of the IPCN requirements.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved upon the initiation and training completion of IPCN number 76 on July 10, 1980.

k NUCLEAR REGULATORY COMMISSION - ITEM B Corrective Steps which Have Been Taken:

This item was corrected per AWS D.1.1, paragraph 3.7.2.2 which allows utilization of a repair method.

The repair work was accomplished and documented by *be responsible Quality Control Inspectors.

Final acceptance followed the performance and acceptance of a liquid penetrant inspection.

o Attachment !

Page 3 of 3 Corrective Steps Which Will Be Taken To Avoid Further Violation:

The violation detected has been determined to be an isolated case and does not occur on a frequent basis.

To avoid any further violations Interim Procedure Change I!otice (IPC:;) number 76 to Construction Procedure (CP) 05, was initiated to more clearly define inspection and documentation of Structural Steel connections.

Also, the civil / structural contractor has implemented the use of weld maps to identify welded connections or welding to structural steel.

In order to assure that all welding Quality Control Inspectors were aware of this situation, a training class was conducted pointing

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out the detection and repair of under cut in base metals.

Date When Full Compliance Will Be Achieved:

Full coroliance was achieved when the final inspection reports were received, for the repair work, on July 17, 1930.

Foilow up training was given on September 17, 1980 for future occurrences of this situation.

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