ML19344A571
| ML19344A571 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/12/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Lewis M AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19344A572 | List: |
| References | |
| NUDOCS 8008210166 | |
| Download: ML19344A571 (1) | |
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Dear Mr. Lewis:
JYoungblood AFerguson Your note to Comissioner Gilinsky dated July 9,1980, has been forwarded to this office for a reply.
In your note, ycu requested a copy of an NRC remo stating that the WPPSS construction pemit license does not guarantee an operating license.
I presume you are referring to the recent enforcement action taken by the Office of. Inspection and Enforcement against the WPPSS organization in light of unsatisfactory work perfomed at the WNP-2 facility.
In particular, OIE proposed to impose civil penalties in the cumulative; amount of $61,000 on June 17,1980, (Enclosure 1) and on that same date, issued a request for infomation pursuant to Section 50.54(f) of 10 CFR Part 50 (Enclosure 2).
This information to be submitted in thirty days, would permit us to determine whether further enforcement a.: tion such as suspension, modification or revocation of the WNP-2 const uction permit would be required.
I am not aware of any internal memo re arding WNP-2 stating that a CP does not guarantee an operating license,, However, this statement is quite true; the issuance of a CP does not guarantee the issuance of an OL.
I trust I have satisfactorily answered your question on this matter.
Sincerely, t
I' 0: @ s W ped Y aron N Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Ltr dtd 7/17/80 fm V. Stello
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NRC FORM 318 (9-76) NRCM 0240 D U.S. GOVERNMENT PRINTING OFFICE: 1979-259 369
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ENCLOSURE 1_
=r JUN 17 580 Occket No. 50-397 EA-80-20 Washington Public Power Supply System ATTN:
Mr. N. O. Strand Managing Director P. O. Box 968
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Richland, Washington 99352 Gentlemen:
The apparent items of nonce:pliance listed in Appendix A to this letter were identified during our investigation of construction activities at the Washington Nuclear Project No. 2 and at your contractor's shops in Seattle, Washington.
This investigation was conducted between November 27, 1979 and February 28, 1980.
Several items of noncompliance described in Appendix A concern the sacrificial shield wall and pipe whip restraints and clearly show that significant problems existed in your quality program during the fabrication of these structures at your contractor's Seattle shop during the period 1975-1978.
Furthermore, recent reinspections of these structures revealed defects which require major repairs and analyses before the structures can be declared acceptable for service.
Notably, the sacrificial shield wall was constructed and certified correct by your contractor although the >pper and lower sections of this structure were not properly welded together.
Consequently, the structure as built is incapable cf withstanding the shear forces postulated during accident conditions.
The failure to detect such deficiencies until this late date represents failures of not only the contractor's quality program but also those of.the Architect Engineer / Construction Manager and the Washington Public Power-Supply System.
Compounding these conditions is that significant deficiencies in the shield wall were identified to you in November 1978.
As of October 1979, these had not been adequately investigated nor an effective
- rrective action program developed.
Moreover, in the Management Meetings of May 18, 1978 and June 6, 1978, we expres-sed our concern with the effectiveness of your quality assurance program to con-
, trol contractor activities for areas other than those contained in Appendix A.
These same concerns were reiterated during a meeting with you on April 24, 1979.
The enclosed items of noncompliance raise a question concerning the adequacy of your control of the quality assurance program in accordance with criteria I, II, XVII, and XVIII of Appendix 3, 10 CFR 50, and paragraphs D.1, 0.2.5, and D.2.7 cf your quality assurance program described in the PSAR.
Consequently, in addition to the civil penalties described below I have issued the accompanying 50.54(f) letter to seek additional information about the quality of the work at your facility before making a determination whether or not to take further action.
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Washington Public Power Supply -
Systea As you are aware from the " Criteria for Determining Enforcement Action," which was provided t.o you by letter dated December 31, 1974, the enforcement actions available to the Commission in the exercise of its regulatory responsibilities include administrative actions in the form of written nctices of violation, civil monetary penalties and orders pertaining to the modification, suspension or revocation of a license. After careful evaluation of the items of noncompliance identified in Appendix A and other results of our investigation conducted between November 2,7, 1979 and February 28, 1980, this office proposes to impose civil penalties, pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, (42 USC 2282) and 10 CFR 2.205, in the cumulative amount of 561,000 as set forth in the " Notice of Proposed Imposition of Civil Penal-ties," enclosed herewith as Appendix 8.
This letter also reaffirms our Immediate Action Letter of November 21, 1979, which specifies that no repairs or attachments shall be made to the sacrificial shield wall until the correc-tive action plan has been reviewed by the NRC staff.
You are required to respond to this letter within twenty-five days, and in preparing your response you should follow the instructions contained in Appendices A and B.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the Nuclear Regulatory Commission's Public Document Room.
Sincerely, M
Victor Stello, Jr.
Director Office of Inspection and Enforcement
Enclosures:
1.
Appendix A, Notice of Violation 2.
Appendix B, Notice of Proposed Imposition of Civil Penalties cc w/Enclorures:
M. E. Witherspoon, Division Manager Quality Assurance, WPPSS W. C. Bibb, Manager, WNP2 Project, WPPSS Glenn C. Walkley President, Board of Directors Route 5, Box 5010 Pasco, Washington 993001 e et u 6
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2 JUN 17 500 Washington Public Power Supply $ystem l
l Health Services Division Department of Social & Health Services ATTN:' Robert C. Will Radiation Control Program MS LD-11 Olympia, Washington 98504 Office of the Attorney General ATTN:
Hon. Slade Corton Attorney General' Temple of Justice Olympia, Washington 98504 Utilities and Transportation Commission ATTN:
Robert C. Barley Chairman Highways-Licenses Bldg.
Olympia, Washington 98504
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APPENDIX A NOTTCE OF VIOLATION Docket No. 50-397 Construction Permit No.: CPPR-93 EA-80-20 Based on the results of NRC investigation conducted between November 27,1979 and February 3,1980, it appears that certain of your activities were not conducted in ell compliance with conditions of your NRC Facility License No.
CPPR-93.
The NRC investigation revealed significant deficiencies in your quality assurance program, in that work performed by contractors and subcontractors did not conform to the criteria of 10 CFR Part 50, Appendix B, as described in Appendix 0 of your PSAR.
Specifically, as of November,1979, the items listed below had not been identified nor corrected.
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 QA Program states in part, that " Activities affecting quality... shall be accomplished in accordance with these instructions, procedures, or drawings...."
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... also remove temporary shims before welding...."
Contrary to the above requirements, on June 14, 1978, assembly of the sacrificial shield wall in the reactor building was completed with temporary shims still in place at the interface of the bottom segment ring beam and the top of the box ring beam.
These shims prevented several slot welds from joining the ring beams.
DUPLICATE DOCUMENT This Violation resulted i j performingitsintendeds.jl Entire document previously cuake conditions and certi_
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v APPENDIX B NbTICEOFPROPOSEDIMPOSITIONOFCIVILPENALTIES Washington Public Power Supply System Docket No. 50-397 EA-80-20 This Office propo.ses to impose civil penalties pursuant to Section 234 of the A,tomic Energy Act of 1954, as amended (42 USC 2282), and to 10 CFR 2.205 in the cumulative amount of Six'ty-one Thousand Dollars for the specific items of noncompliance set forth in Appendix A to the cover letter.
In proposing to impose civil penalties pursuant to this section of the Act and in fixing the proposed amount of the penalties, the factors identified in the Statements of Consideration published in the Federal Register with the rulemaking action which adopted 10 CFR 2.205 (36 FR 16394) August 26, 1971, and the " Criteria for. Determining Enforcement Action," which was sent to the NRC licensees on December 31, 1974, have been taken into account.
The Washington Public Power Supply System may, within twenty-five days of the date of this Notice, pay the civil penalties in the cumulative amount of Sixty one Thousand Dollars or may protest the imposition of the civil penalties in whole or in part by a written answer.
Should the Washington Public Power Supply System fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the amount proposed above.
Should the Washington Public Power Supply System elect to file an answer protesting the civil penalties, such answer may (a) ceny the items of noncompliance listed in the Notice of Violation in whole ci in part; (b) demonstrate extenua-ting circumstances; (c) show error in the Notice of Violation; or (d) show other reasons why the penalties should not be imposed.
In addition to protes-ting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
The Washington Public Power Supply System's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to answer and ensuing orders; answer, ca.nsideration by this office and ensuing orders; requests for hearings, hear ngs and ensuir.g orders; compromise; and collection.
Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, the l
matter may be refert ed to the Attorney Gereral, and the penalty, unless compromised, remittel, or mitigated, may be col.lected by civil action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended (42 USC 2282).
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ENCLOSITRE 2
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JUN 171580
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6 Cocket No. 50-397 EA-80-20 Washington Public Power Supply System ATTN:
Mr. N. O. Strand Managing Director P. O. Box 968 Richland, Washington 99352 Gentlemen:
Subject:
10 CFR 50.54(f) Request Regarding Quality Assurance As discussed with members of WPPSS management during a meeting at your head-quarters office on May 30, 1980, and as detailed in the Notice of Violation which accompanies this letter, the NRC staff is concerned about the quality of construction at your Washington Nuclear Project No. 2 (hhp-2) site.
Specifi-cally, the IE staff does not at this time have sufficient information to conclude that WNP-2 has been constructed in substantial conformance with the construction permit.
Several items of noncompliance described in the Notice of Violation concern the sacrificial shield wall and pipe whip restraints and clearly show that significant problems existed in your quality program during the fabrication of these structures at the Seattle shop of your contractor, leckenby Corp.,
during the period 1976-1978.
Furthermore, recent reinspections of these structures revealed defects which require major repairs and analyses before the structures can be declared acceptable for service.
Notably, the sacrifi-cial shield wall was constructed and certified correct by your contractor although the upper and lower sections of this structure were not properly welded together.
Consequently the structure as built may be incapable of withstanding the shear forces postulated curing accident conditions.
The failure to cetect such deficiencies until this late date represents failures of not only the contractor's quality program but also those of the Architect Engineer / Construction Manager, Burns and Roe, and the Washington Public Power Supply System.
Compounding these conditions is that significant deficiencies in the shield wall were identified to you in November 1978, and as of October 1979 these had not been adequately investigated nor an effective corrective action program developed.
Moreover, in the Management Meetings of May 18, and June 6,1978, Region V. representatives expressed their concern with the effective-ness of your quality assurance program to control activities of your contractors or subcontractors, of whom there are approxi=ately thirty at the WNP-2 facility.
These concerns were reiterated during a meeting with you on April 24, 1979.
By the end of 1978, in excess of twenty specific items of noncompliance had been identified at kNP-2 by the NRC.
During 1979 sixteen ite=s were cited in addition to those covered in the accompanying Notice of Violation.
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2 JUN 17 GO Washington Public Power Supply -
System review and analysis of these numerous items of noncompliance and related inspection findings indicate a common problem: ineffective control by WPPSS and Burns and Roe of the activities of contractors without NRC reviewed quality assurance programs.
In addition to Leckenby Corp., the contractors or subcon-tractors demonstrating ineffective control include: (1) Wright, Schuchart, Harbor, Boecon, GERI; (2) Waldinger; (3) Seattle Industrial; (4) Industrial Heating and Plumbing; (5) Johnson Controls; and (6) Fischbach-Lord.
The pattern and seriousness 'f noncompliances at WNP-2 are cause for our
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o concern whether work in portions of the facility in addition to that worked by Leckenby Corporation has been properly accomplished and whether current and future work is being adequately controlled.
Therefore, under the authority of Section 182 of the Atomic Energy ' :t of 1954, as amended, and Section 50.54 (f) of 10 CFR Part 50, information is requested on the steps which will be taken to provide reasonable assurance that your approved quality assurance program has been implemented such that structures, components, and systems, constructed by contractors not having an NRC reviewed quality assurance program are in accordance with conditions of your construction permit and those steps which will be taken to strengthen management control of the project.
Accordingly, submit within thirty days a plan and schedule for completion of review of completed safety-related work accomplished by those contractors not having an NRC reviewed quality assurance program to determine whether the quality assurance program was adequate to assure such work was properiv performed.
The depth of review should be commensurate with the safaty function of the structures, systems, or components and should include, but not necessarily be limitad to, the following considerations:
a.
Were there cases where the required quality procedures and specifications were not applied to the work?
b.
Were there instances in which improperly qualified personnel performed and inspected the work?
c.
Were receipt inspection requirements followed for contractor produced items and why weren't deficiencies detected.during receipt inspection?
i d.
Were correct dispositions made for nonconformance reports, design l
changes, field change reques'.s, and information requests?
e.
On the basis of review of existing records and a sampling of pre-viously inspected work, are quality and test records associated with the work complete and accurate?
The plan should include: (1) the rationale for selection of contractor item (s) for review, (2) provision for reporting results of the revie'
) the NRC, (2) provision for reporting to the NRC repairs or further action to be taken for i
gg 17 N Washington Public Power Supply 3-System those structures, systems, or components which are found to be deficient or questionable as a result of the review, and (4) provisions for evaluating the quality assurance programs at each of the WPPSS facilities based on lessons learned f om the review.
You are required to respond to this letter under oath or affirmation.
In ti.ost cases in' which a complete response must await the results of future accivities, an interim reply shall be given within thirty days as well as the associated schedules for completion of the response.
We are continuing our investigations into quality assurance matters at your facility.
Your reply to this letter and implementation of corrective actions, as well as the results of our most recent investigations, will be considered in determining whether any further enforcement action is re > ired (such as s
suspension, modification or revocation of your license).
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the Nuclear Regulatory Commission's Public Docunent Room.
Sincerely,
/s/
Victor Stello, Jr.
Director Office of Inspection and Enforcement
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