ML19350E397
| ML19350E397 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 02/19/1981 |
| From: | Dobson D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19350E394 | List: |
| References | |
| GO3-81-511, NUDOCS 8106220408 | |
| Download: ML19350E397 (6) | |
Text
'.
.h' 1
PP W shington Public Power Supply Systam A JOINT OPERATING AGENCY S
- r. o. soi 32n uua. w aswi~ctos ses4i ruost 2o6124,.sooi g$ $ -
February 19, 1981 y
If $ $,>6QU G03-81-511 R
Nuclear Regulatory Commission, Region V H
J P fi Suite 202, Walnut Creek Plaza 6
Y s
6i 1990 N. California Boulevard TA b
d Walnut Creek, California 94596 c
Attention:
Mr. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch Gentlemen:
Subject:
WPPSS NUCLEAR PROJECTS 3 AND 5 NRC INSPECTION AT WNP-3 AND WNP-5 DOCKET NUMBERS 50-508 AND 50-509
References:
- 1) Letter, G. S. Spencer to F. D. McElwee, NRC Inspection at Washington Nuclear Projects Nos. 3 and 5, dated January 9,1981.
- 2) Letter, D. E. Dobson to R. H. Engelken, same subject, dated January 29, 1981.
- 3) Letter, D. L. Renberger to G. S. Spencer, WPPSS Nuclear Projects 3 and 5, same subject, dated July 11, 1980.
- 4) Letter, 4EB-80-131, L' Ray Jorgensen to Manager of Projects, Defective Welds and Mismatch on ASME Pipe Spools, dated August 22, 1980.
- 5) Letter, 4EB-80-90, L' Ray Jorgensen to Manager of Projects, Defective Welds and Mismatch on ASME Pipe Spools, dated June 27, 1980.
This letter is in response to your letter of January 9,1981 which discussed the results of the inspection conducted November 18-21, 1980 of activities authorized by Nuclear Regulatory Commission Construction Permit Numbers CPPR-154 and CPPR-155. The letter identified two items of noncompliance and required the Supply System to provide a response to these items.
8106220h0I SI-18'
- s'*'
1 e
lMr.'G.i. spencer!
Februari 19. 1981 S
l
'Page 2 G03 81-511
- yj!/
i,;12 It L The -specific Nuclear ~ Regulatory Conmission 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, PDC D. E. D0BSON Acting Program Director, WNP-3/5 -
~
Attachments cc:
D. SefU1 peter - BPA Ebascs - New York WNP-3/E Files - Richland
)
l i-4
((
%g ATTACHMENT I NUCLEAR REGULATORY COMMISSION VIOLATION A 10CFR50,' Appendix _ B,- Criterion.V. as implemented by Section 17.4.5 of the Quality Assurance Program documented in the approved PSAR deviation 18-WP, states, in part, that " Activities affecting quality...shall be accomplished-in accordance with... instructions, procedures or drawings."
Specification No. 3240-4, titled " Piping and Piping Supports - WPPSS Quality Class I, II and G," in Division 2, Section 2A, Paragraph-6.01a states that "All-fabrication covered by this specification shall be in accordance.with ASME Section III" and further states in Paragraph 6.0ld-iii that "The. ends of the
. pipe-to-pipe pipe-to-fitting, and pipe-to-valve joints shall be aligned.as accurately as practical within the existing commercial codes and standards tolerance of pipe diameters, pipe wall thickness, and out-of-roundness." The ASME B&PV Code,1974 Edition, Summer 1976 Addenda, Subsection NC, Table NC-4232 (a)-1 specifies a maximum allowable offset in final welded circumferential joints of 1/4 t where t is the nominal thickness of the thinner section at the
-joint and is less than or equal to.1/2 inch.
Contrary to the above, on November 19, 1980 at the Saginaw storage area, circum-ferential shop weld "A" on piping subassembly No. 3-2CH-20-150-2 had a five (5) inch long area of internal offset measuring 3/16 inch. This offset is twice the aforementioned code allowable maximum offset of 3/32 for this thickness pipe
(.375 inch). This piping had been accepted by the site receiving inspection organization.
This is a Severity Level V violation and is applicable to Docket No. 50-508.
Corrective Steps Which Have Been Taken And The Results Achieved:
Site nonconformance report number 12475 was initiated on November 19, 1980 to document the noted condition.
Letter, G03-80-3088 was prepared to notify Associated Piping and Engineering Corporation (AP&E) of the offset violation on December 8,1980. This letter required AP&E to provide written response to this violation. AP&E responded to G03-80-3088 on December 30, 1980 via letter 4EB-80-246. This correspondence
. proposed a corrective action to spool 3-2CH-20-150-2 of grinding the question-able area to a three to one taper.
NCR 12475 reflects a recommended disposi-tion of "Other Rework", return to contractor and referenced letter 4EB-80-246.
Corrective Steps Which Will Be Taken To Avoid Further Items Of Noncomoliance:
References 4 and 5 detail AP&E's corrective action with respect to Clearfield produced ASME Section III spools. On-site Compton supplied ASME Section III spools will be reinspected by AP&E personnel. Nonconforming conditions will be documented on a site nonconformance report. Their reinspection will be limited to spool accessible welds which have no "C" dimensions noted on the shop drawings.
y
L, M..
' 2*
~
- w=.,
~
AP&E has committed in'1etter 4EB-80-246 to fair all accessible welds to a three' to one. taper.as part of their normal : fabrication activities.-
The Date When Full Compliance Wil! Be Achieved:
s NCR 12475 disposition evaluation was completed on January 16,1981.
Reinspection of AS!jE Section III_~ spools, supplied by AP&E (Compton), is scheduled for.the
" week off February 8,1981. Any required nonconformance report will be generated -
-.at the completion of the AP&E reinspection. AP&E began in-house fairing of all areas which exceed offset tolerances on' December 1,11980 per 4EB-80-246..Because.
of the type of noncompliance _a date for full. compliance.cannot beJspecified.
NUCLEAR REGULATORY COMMISSION VIOLATION B 110CFR50,~ Appendix B, Criterion V, as implemented by-Section 17.4.5 of the Quality.' Assurance Program documented in the approved PSAR deviation.18-WP, 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 accordanca with these instruc-.
tions, procedures, or drawings."
Contract specification'No. 3240-265, " Reactor Building Concrete Construction",
the governing specification for the contractor's (J. A. Jonts-Construction Company) work activities on the reactor building, states in pragraph 14.6.4 that for nonconformance reports, " Contractor shall submit the original completed nonconformance report with applicable supporting engineering and inspection documentation to Engineer's Quality Assurance Site Supervisor." Paragraph 14.6.6 states: that, "For NRB reviewed nonconformances, Engineer shall also witness the reinspection, determine its acceptability and sign off the nonconformance report after. prinr contractor inspection and approval."
. Contrary to the above:
The following documented procedures, implementing contract specification no.
3240-265,~ did not include appropriate requirements of the specification in that:
1)
J. A. Jones Procedure No. P0P-N-703, t'tled Nonconformance Reporting, does not include the requirement of the contact specification that, for contractor dispositioned nonconformance coorts, the contractor shall submit the original completed nonconforma tce report with applicable supporting engineering and inisction docuaentation to the Engineer's Quality Assurance Si.te Supervisor.
Nonconformance Report Nos. 2907 and 2910, dated hay 5 and 9,1980, were dispositioned by J. A. Jones, but the supporting concrete inspection reports and final placement records were not submitted to the Engineer's Quality Assurance Site Supervisor.
.2)
J. A. Jones Procedure No. P0P-N-703 and WPPSS/Ebasco Administrative Site Procedure No. ASP-QA-7-3, prescribing the controls for owner / engineer evaluation and disposition of nonconformance reports, do not include the requirement that the Engineer shall witness and determine the accept-ability of the reinspection and sign off the nonconformance report for nonconformances reviewed by-the Nonconformance Review Board (NRB).
3; _ y.5
.v yV 3-
^
J. A.; Jones Nonconformance Report Nos.?2910 and L2900, dated.May. _9 and -
i 1 September 116,"1980, were reviewed by the' NRB,, but these. reports were not.
signed off,by the Engineer attesting the' witnessing-and: acceptability of;the reinspection.
W
/ "
'This is a Severity Level Viiolation'andLis applicable to-Docket Nos.-
gff '
50-508 and 50-509.
' Corrective Steps Which Have Been.Taken And The Results Achieved:
1
- 1) The' supporting-documentation for NCRs. 2907 and 2910 was submitted to the'-
L0wner/ Engineer ? January 5,.1981 on tran!mittal NCR-QA-80-003 and.
~
^
-NCR-QA-80-005.
- 2)~ The Engineer hasireviewed paragraph 14.6.6 of' Contract-3240-265, 2A Section.
.This requirement has been evaluated:and found unnecessary as reinspections-are witnessed by Contractor Quality Control for acceptability. This Require-ment will be deleted from a111 Quality. Class I ccntracts.
i
~
Corrective Steps Which Will Be Taken To Avoid Further Items 0f Noncompliante:
1)'JJ:A. Jones Procedure P0P-N-703 has been revised and is with the Engineer for review and comments, and now requires: supporting documentation.to be.
attached to nonconformance reports. The revised P0P-N-703 was.sent-to the
-Engineer.on February -19,.1981 on transmittal T-474.
I
- 2)' ) Engineer ! Quality Assurance ~ has reviewed all Quality. Class ~ I contracts for-nonconformance control. procedure requirements. This review will result in i
contract modifications withLrespect to nonconformance controls, and will
-provide standardization in these arcas.
- The' Date When-Full Compliance Will Be Achieved:
- 1) The revised P0P-N-703 will 'be imp 1emented by' April 1,1981.
~
2).,Co,ntract modifications incorporating the revised requirements for noncon-i form 1nce control.will be effective by June 1,1981.
F e
s 5
5 T
% ~
9 4
4 4 h m t-w
-e t
71-e v-
- 2*
W v
4 w-v-
"*'vv&ww*-
T
(,_,,.
~...
- db
~
~
z
.D.: E. DOBSON, Being' first duly sworn,' deposes and says: That h'e is the Acting Program Director, WNP-3/5,.for the WASHINGTON PUBLIC
- POWER SUPPLY. SYSTEM, the applicant herein; that he_is authorized
'to submit the foregoing on behalf of said applicant; that he has :
read th~e foregoing.and knows the contents thereof; and believes :the same to be true to the best of his knowledge.
DATED Tbaaoneu /Cl
, 1981.
J 0
e
~
.D.
E. D0BSON STATE OF WASHINGTON
)
-) ss COUNTY OF GRAYS HARBOR)
On this day personally appeared before me D. E. D0BSON 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.
GIVEN under rny hand and seal this 19 @
day of eenogmi
, 1981.
I M
,6ts n Notary Public'in and for the State of Washington Residing at Elrna
.S L