ML20010H707
| ML20010H707 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 07/15/1980 |
| From: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Reinmuth W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML17272A975 | List: |
| References | |
| FOIA-81-223 NUDOCS 8109290173 | |
| Download: ML20010H707 (14) | |
Text
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'o UMTED STATES E
~,$
NUCLEAR REGULATORY COMMISSION g
.E' REGION V
,A
[
1990 N. CALIFORNIA BOULEVARD o#
SUITE 202, WALNUT CREEK PLAZA WALNUT CREEK, CALIFORNIA 91596 JUL 151980 MEMORANDUM FOR:
W. G. Reinmuth, Assistant Director, Division of Reactor Construction Inspection FROM:
G. S. Spencer, Chief, Reactor Construction and Engineering Support Branch
SUBJECT:
REQUEST FOR REVIEW 0F WPPSS EVALUATION OF SHEAR STUDS EXHIBITING A HIGH FAILURE RATE AT WNP-1/4 (AITS NO. F05030009)
During an inspection at Washington Nuclear Projects Nos.1 and 4 in October 1978 the NRC identified improper installation of shear studs which resulted in an item of noncompliance (NRC Report No. 50-460/
78-07).
In responding to the item of noncompliance the licensee found a comparatively high failure rate for studs welded through metal decking to structural members (WPPSS letter G01-78-897 of December 11, 1978).
In followup to the item of noncompliance, the inspectors expressed concern for the dispositioning of those studs welded through the metal decking which were now embedded in concrete (NRC Report No. 50-460/
79-01). The licensee agreed to formally evaluate this condition.
The evaluation has been completed and is documented in a United Engineers and Constructors report entitled " Investigation of Studs", dated May 1, 1980.
It is requested that IE;HQ provide for a technical review of the licensee's evaluation of the acceptability of those WNP-1/4 structures which contain embedded shear studs which were installed through metal decking.
Excerpts from the pertinent NRC inspection reports, licensee correspondence, and the licensee's final repor'
' enclosed.
The generic aspects of stud welding through metal decking is addressed under AITS No. F50013H1.
G. S. Spencer, Chief Reactor Construction and Engineering Support Branch
Enclosures:
(1)ExcerptfromNRCRpt. 50-460/78-07 (2)WPPSS ltr G01-78-897 of 12/11/76 (3)ExcerptfromNRCRpt. 50-460/79-01 (4)UE&C Rpt, " Investigation of Studs," 5/1/80 j
CONTACT:
D. F. Kirsch (463-3723)
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8109290173 810805 PDR FOIA BRYAN 81-223 PDR
~~~!ASA*7"~-~'N-3
_w IF-BOLLF~i1MS M/DATEl EFe/ DOE l Rm.y ocE c:snecr Acach /sn.To's st 79705/Vak N.A.
(n1T)
- Ynfo -
__.- )
C 79-06/ Var.
'N.A.
(D1I - PWRS)
- Not Applicable -
C'
- 1 '
.79-07/4149 s799 Anno 3n,
._ of q _,,
t,,,
4 9 -08/4149 N.A.
(Dif - BWRS)
- Tnfn
.T nn o Torm e.
70_ng/A17o 6179
_6179 (crT nun h iluzes) c^=ponent.-not-used 4--WF-2 0.
79-10/5119 N.A.
_(Requal TR Prop. Krari s ti cs)
- Mnr Applienkle -
r*.
~
1 79-11/5229 7229 8069
_(Ignity Qgercorr.
Trip n vice) cnmpnnent n n e u sn a @k'NP-7 C.
e 79-12/5319 N.A.
(BVR Scrams)
Reviewed by WPPR9 OPR c'
. 79-13/6259
-N.A.
(Feedwater Pie.e Cracks-PWRS)
- Nne'Annifenkle -
c' 79-14/7029 NO29 9/7 + 9119 (As-Built Seismic Annlys.)
- Working 0.
79-15/7119 9119 9189 (Deen _DRFT Pumo Defys) - An t ring Suppliers Data 0; 16/7269 92'19 9059 (Vital Area Access Centroll-Ren1
- Ref s Phym Spenrity Pin -
79-17/7269 N.A.
(PWR Borated H 0_ Pipe Cracks)
Nnt pplienkle -
C' 2
79-18/8079 N.A.
(Audib. Prob on Evac)
- Not Ann 1(cah19 -
C' 79-19/8109 N.A.
(Pkst Low Level Waste)
- Not nnlienble -
(*
79-20/8109 N.A.
(Pk g Low Level Wa s t ed-Ma r l. Li c. ) - Not Annlienble -
FI y9-21/8139 N.A.
ITgnp. Ef f ec_tS_.on 1evp1 Menc) Raviound/Nn Prnh 0 FNP-7 c'
'75122/9059 N.A.
_(Ird tium Cas Lke-Marl. Tfc.)
- Une Ann 14cnh10 -
C'
,j9-23/9129 0279 N029 LEailures of D,G_ _ Field Ex. mf RT Revipued og prnh C'.
79-24/9279 N.A.
(Frozen Lines T Reviewed /Nn Prnh 9 WNP-7
(*
79-25/N029 1020
( W B.EDJ_elay_Iail roi Cnnponent nnt n=ad O WNP-?
r-79-26/N209.
N.A.
LB.gran_ Loss - EUR Centrni Rnd R1dni
- Roviound c'
79-27/N309 N.A.
{lo_ss of NON TE_Tnstrum.T
- Unrkino~
0-79-28/D079 2070 1280 IPoss. Limit Swi t ch Prob'LCorponent e nnt need.J_NNP 7 e
p 79-01B/1140 N.A.
.(Invir.._ Qual _Equipi
_ Working - -
-.ns 79-171/0299 N.A.
(ElmlpIate.d_U 0_. Cracks)
- Nnr Applienh19 -
_C1.
2 79-1_44/9079 N.A.
(Gu.idan.ce.As.-huil t Sesinic AnnlysisL (Tn fn. f or. 79=.14)
C'.
79-03A/4040 8040 '_
. (Op ep)_
(long,_Je.1d jleiec.ts).
- Unrking -
0;.
79-01B/2290 N.A.
___.__ -..._._._ (Env.ir.p_q Qua1._.Equipl_ :. Working. -
_. 0;.
'0-01/1110 N.A.
(Ms.2_Lil_ Op er.phil,i ty.)_._- _Wo rk i ng -
.... _. O p.
8
,80-02/1210 5210
_(Op_e n)
(.Isade.L Srpplier_ QA1
- UnIking -
-- 0: !
80-03/2060 3210
_3180 (Los s..o f,_ Cha r.c oal.)_
- Working -
C 80-04/2080 N.A.
(PFR Ja.in..Lin e.Bk).
- Not_Applicabla -
C'
.80,-0_5L3100
,N. A._,._ _,,_
(CyCS.TK.. Damage)__.
_.Worki ng.. __._ -__ _
0-80-06/3130 N.A.
__ (ISF Res.et ContrL... __..- Working.-
-. C: i
,80-07/4040 N.A.
(Je.t_P.pmp JaF Jre)
. _. Working _
C; Q_0,-08/4070 ~
707_0 (Open)_ __ (Exns_of_ Cont _ Liner Pene.We i de)._ _ Working,-
.. C:
S0-09/4170 6170
..(Open)
(Hydromotor Actus.torsl.- WoJking_-
C; !
IExtcasion Req 2csted/ Grant ed '
I e
m
-+
lE CidCOLo.e5 3
_._l. EC /Dri c t'orzescmvs AcnoN/SWG)S STATr
, 't'79-06/_4129 Not Applicable C1sA 79-07/5029_
Component not used @ WNP-2 Cisd 79-08/5189
_(Extortion)
Not_ A_pp_1.icable C1 sui _
79-09/6229
_(SCBA Problem)
- Workine -
Onen
~
79-10/6269
_(t!na,ccep. Pipe Ftes)
- Workine -
Open 79-11/6279
,(D_e_ sign / Cons t. Interface Prob) - Workine -
Onen 79-12/6289 (D.C._T_urboche Prob)
- Workine -
Onen 79-13/7139 (Fire Pump Contactor Prob)
Defective parts replaced C1sd 79-14/7139
_(Unauthor. Procur. Xenon-133) Not applicaole Clad 79-15/8089 (SCBA Prob)
- Workine -
Onen 79-16/8169 (Over Exp. Radiographer /Public) Not Applicable C1sd 79-17/8149 (G.E. Ckt. BRR Prob)
- Workine -
Onen 79-18/9109 (Imoroper Install of SRV)
- Workine -
Onen 79-19/9139'
_(Loose Locking Devices / Pumps)
Not a oroblem with OI p_ urns C1=d 79-20/9249
_(. Relay Fai.
e)
- Workine -
Onen 79-21/0199' (Unolanned rtlease)
- Workine -
Onan 79-22 /N169
,(POV Stroke Times)
- Workine -
Opan.
t....
j79-23/N269 (Starter /Contactor Failures)
Coroonent not used 0 WNP-2 clad 79-24 /N269 (Install /Calib CS Pipe BRK Detect,_EO)
Reviewed /a c tion specified c1cd 79-25 /D209 (Shock Arrestor Strut Assy)
Coroonent not used 0 UNP-2 cled 79-25A/1310 (Shock Arrestor Strut Assy)
Compottent not used 9 liNP-2 cled 80-01/117D (CE Service Advice)
- Working -
anon 80-02/2010
,(Staff Wk Hrs)
- Uqr_kJne -
~0 nan 80-03/3060
,(Toxic _Cas Protection)
_ Wor _k.img -
Open _
k 80-0/./3140 (Secgring Thrd Lockin_f,_ De_yices)- Wor. king._
Onnn 80-05/4010,_
(D_G. Lub 011 Addition /Onsite Suppl 1v)
- Working -
Open..- -
__80-06/4140 _
(,Co_g.r_olfAc count. Th e rapy_S o uT_c_e_s_) -_Eqt_Applic a ble Cis d..
80-07/4030 (HPCI Turbine Probs)
- Working -
Ope.n-
.,_8,0__0,8/4180 (BWR Tech _Sp.ec Inconsist.)_,.
- Wqrking -
Open
,' 80-09/4280, (Comm_un.. Syst. Probs)
- Wor _ki_nx -
Open..
80-10/4290 __,
(Fai h _to Maint_._ EnviL Qual _if)_._ Working.-
_ Dpen.
L
',- ATTAChNENT 5
bl%
t& _ ~)
m=>o.5 Me) IleMS
!NITlal Nong P2nfTEN KY)Tif:.-
303.)?Ci -- - ~~-
~~~
~
~--~ --] ~ Cc;2t2FcriCACT.
,,_4/27/79 4/30/79 BIF valve operator may vibr. off shaft
_ Satisfactory 4/27/79 5/31/79 Whip restraint steel defects (Pybus Steel)
_. Satisfactory 5/04/79 5/31/79 Poor soldering W penetration Satisfactory 6/21/79 7/16/79 Ess. fan supplied from noness. source Satisfactory 6/21/79 7/20/79 Quality I equip supported by Quality II steet_, Satisfactory
_ 6/21/79 8/02/79 C.M. Diesel engine problem Satisfactory 6/28/79 8/07/79 Improperly installed anchor bolts _
Satisfactory 9/21/79 10/18/79 ECC pump room flood from fuel pool condensate Satisfactory, work!
10/04/79 10/31/79 Incorrect plug welding between SSW rings 3/4 working 11/21/79 12/1'0/79, Irregularities in pipe whip restraint record ; working 2/19/80 3/19/80 Possible water hammer in RCIC piping Satisfactorv. work:
2/19/80 3/21/80 Potential missiles adjacent to RPS MG sets working 3/19/80 4/21/80 Poor control of small piping design changes Satisfactorv. work; 3/19/80 4/21/80 Improper weld prep of small bore piping working
--(
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7 ATTAC10!ENT 6 I.D.DM-
_S_
._ a 4nnd.uk
-'E-
- 8""**"**
- ~*N
- 06
rs JUSTIFICATION FOR INCREASED INSPECTION FRE00ENCY CONCERN
. EXAMPLES
. 1.-
Questions exist in the The sacrificial shield wall, completed in June,
- acceptability of completed
_1978 has been found to be seriously deficient, safety.related work.
indicating quality controls during the period of fabrication and erection were not as effective 13, 16, 80-04)(IE Inspection Reports 50-397/79-12, as required.
The pipe whip restraints, completed in February, 1977 have been found to be seriously deficient, indicating quality controls during this period were not as effective as required.
(IE Inspection Reports 50-397/80-04)
The postweld heat treatment of pipe welds conducted during the period of February, 1977 to 1979 was found to be seriously deficient, indicating. quality controls during this period were not as effective as raquired.
(IE Inspection Report 50-397/79-10)
The pipe support installation / inspection program 'up to May,1978 was found to be seriously deficient and was the subject of 9 items of noncompliance during Dec.
1977-May 1978, indicating prior quality controls were not effective.
(IE Inspection Reports 50-397/77-07, 78-03,80-06).
HVAC installation (including safety related portions) up through 1978 was found by the licensee to Le sufficiently deficient to require a 100% reinspection.
(IE Inspection Report 50-397/79-04)
In 1978, the licensee fmad piping contractor welding procedures to have nontraceable test results and other problems requiring "re-qualification" of all procedures (IE Inspection Reports 50-397/79-14, 79-16) 2 Licensee control of current Pipe support installation, the subject of 5 items of work activities.
(This noncompliance in 1977, 4 items of noncompliance in 197 concern is fdrther defined 1 item of noncompliance in 1979, is again the subject in items 3, 4, and 5 below). an item of noncompliance in 1980.
(IE Inspection Repe 50-397/77-07,78-03,79-03,80-04).
Ability to maintain component and'equipi.. it cleanlines-continues to be a problem site management has not beer effective in resolving.
Cleanliness was the subject c 4 items of noncompliance in 1979 and on in 1980.
(IE Inspection Reports 50-397/79-01,79-04,79-16,80-04)
(For additional examples refer to items 3 and 4 below)
Aut.tvMCT
'i JUSTIFICATION FOR INCREASED INSPECTION EREOUENCY (cont.)
. CONCERN EXAMPLES 3
-Timeliness of identification NRC identified a concern on the seismic qualification
. of problecs to site and electrical conduit. clamping devices in October 1978.
- licensee headquarters of April 1980, the licensee has still not determined w
- management, and timeliness
. clamping devices will perform to' seismic requirements, of response to problems..
' Some steps were taken in ' January 1980 and April 1980 t-restrict the type of clamping device to those which sh:
the ~ nost promise in meeting seismic testing requiremen-O however, many devices installed between 10/78 and 1/8C require reinspection / replacement.
(IE Inspection Repc.
50-397/78-10, 78-11, 79-04, 79-09,. 80-06)
Electrical separation requirements has been an NRC concern since October 1978.
The licensee's requiremen.
in this area have been changed by the licensee but wer:
not formally submitted to NRR as of April 18, 1980. T latest set of requirements do not appear to comply wit current industry standards and have the potential for resulting in significant rework if disapproved by NRR.
NRC:RV concerns with the new criteria have been for-warded to IE:HQ for submittal to NRR.
Environmental qualification of electrical components "
been an NRC concern since March 1979. While the licensee has been active in this area the actions have not been ccmpicted.
(IE Inspection Report 50-397 79-04).
In August 1979, the NRC pointed out an inconsistency between the PSAR and tha 215 contractor's inspector qualification procedure. As of February 1980, no l
effective action had been taken.
(IE Inspection Reports 50-397/79-14,80-04).
4 L "5 e
G G
e
c JUSTIFICATION FOR INCREASED INSPECTION ' FREQUENCY (cont.)
CONCERN EXAMPLES 4.
Thoroughness in performing Licensee management was advised by their contractor evaluations of. problems, of problems with the sacrificial shield wall in November,-1978.' A corrective action plan was developed and implemented in March,1979.
In June, 1979,.the NRC received allegations concerning the wall.
Investigation at that time established that validity of Leckenby sacrificial shield wall records was in question (a thorough licensee evaluation during November,1978 to March,1979 should have identified this concern).
In July, 1979, the licensee's corrective action' program was expanded to include a quality review of the Leckenby program.
This review was effectively completed by November 30, 1979 without identifying significant problems in Leckenby QA program, which were identified by the NRC investigation of 11/27/79 to 2/28/80.
In addition, in October,1979, the NRC identified that -licensee's engineering review for structural acceptability of the wall (which started in March, 1979, was bei.g performed on an incomplete data base (engineers were plotting / extrapolating typical wall defec+s in lieu of all actual known defects).
(IE Ins 50-397/79-12, 79-13, 79-16, 80-04) pection Reports Licensee reported major defects in Leckenby electro-slag welds for certain pipe whip restraint brackets in a 50.55(e) item in March,1979.
Of the 45 brack-ets fabricated 20 had to be completely rebuilt,14 were repaired, and 11 were found acceptable.
The licensee's evaluation of the problem failed to address other electroslag welding done by the same contractor for WNP-2 (i.e., the sacrificial shield wall and pipe whip restraints) which turned out to have significant welding deficiencie as well as major quality p"oblems.
A thorough evaluation should have surfaced many of the teckenby problems later identified by the NRC.
(IE Inspection Reports 50-397/79-06,79-12,79-13,79-16,80-04).
5.
Although the licensee has Refer to item 2 above for examples, made significant improvements in training with their Q-Tips program, further improvement
-is warranted in the. licensee's program for personnel training
.and problem feedback in view of the repetitive nature of several items of noncompliance during the -past year.
7 7t.
.,Li,.
Tdl SHOP i
- (r D/N 50-397
/18/79 l
T EVALUATION OF WPPSS. PERFORMANCE RE:
WNP-2 CONSTRUCTION ACTIVITIES
- 1. ~ General Recent'NRC inspections and investigations of construction activities at WNP-2 have identified ~an increasing number of quality problems.
C,.
WNP-2 is reported to be approximately 65% complete overall, with
~
major contractors at or.near this level (e.g., mechanical contract 68%. alectrical 84%, instrumentation 50%).
It is of concer~n that th_ individual contractors activities are not proceeding in a smooth and effective manner at this advanced stage of construction.
Accentuating this concern is the fact that licensee management has not been effective in correcting the underlying problems, contributing to the situation, notwithstanding the HRC enforcement conferences of.
May and June,1978 and the licensees presentation to the NRC in
-February, 1979.
2.
Enforcement History - (see Enforcement History Graph)
WNP-2 enforcement activity in 1978 reflected some improvement over 5=-
1976 and 1977, when considering the number of items of noncompliance
~
(.
per. onsite inspector hour. The first quarter of 1979, however, indicates a deterioration in licensee performance.
3.
Specific -Problem Areas Four areas have been identi.'ied as specific problems at the WNP-2 site, these are:
Contractors with significant quality deficiencies have been allowed to perform quality class I work.
i In the past six months there have been two major contractors (HVAC and Instrumentation Installation)' which have encountered
, quality problem but proceeded to perform quality class I work without sufficient compensating actions:
(1)
In August, 1978 the licensee identified the failure of the HVAC contractor to perform audits of his subcontractors.
The subcontractors had been performing quality class 'I work since March,1978 with no audits by the prime contractor.
In October,1978 the licensee identified significant problems with other aspects of the HVAC contractors quality program. *These problems necessitated rewriting and resubmittal of all of the l
contractors quality implementing procedures, and retraining of the contractors personnel. 'During this period of time the
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ATTACHMENT 2 s
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,.. = =
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contractor and his cubcontractors continued to perform quality class I work.
Due to the lack of auditing significant quality
~
problems went undetected in one subcontractor's area (NRC Inspection report-50-397/79-03).
In addition, the HVAC contractor continues to experience quality problems (NRC Inspection
~
reports 50-397/79-06&07);
(2) In August,1978 the NRC inspection of the instrumentation contractor pointed out that the contractor needed to develop certain procedures prior to the start of quality class I work.
By schedule, the contractor planned to start class I work the first week in January,1979. - A NRC re-inspection of the contractor during that week revealed additional procedures which needed to be approved and implementation acti~ns which o
needed to be completed before the start of ch s I work.
Class I work started.in late January,1979.
NRC inspection of the contractor on March 1, 1979 revealed significant problems with the contractors quality program (50-397/79-04).
It appears from these two instances that the licensee was not
~E=
sufficiently aggressive in controlling the conduct of quality
~
. class I work at a time when quality problems were known to exist.
i b.
Excessive time is required to correct identified deficiencies.
~
The following examples represent situations where the licensee i
l has taken an inordinate amount of time to correct quality program deficiencies.
(1)
Pipe support installations - In December 1977 the NRC l
identified major problems in the area of pipe support install-ations. The licensee took some action at this time, but it l
was ineffective.
In May,1978 the NRC again identified the same l
major problems with pipe support installations.
Reinspection
, of this area in October, 1978 indicated the problems had still l
g not been fully corrected.
The NRC concerns were finally resolved l
in January,1979.
(2)
Component cleanliness - In April,1978 the NRC expressed concern regarding"the' cleenliness of installed co'mponents.
Some licensee actions were taken but in October,1978 problems continued to exist: -In January,1979 the NRC found additional
~
cleanliness violations.
As of April 5,1979 the licens'ee had
' still not implemented his revised program to maintain cleanliness control.
.-F.
~~~
..s 3..
- =..
,5 f (3). Tape control - In Octoheh, 1978, during an inspection to0r the NRC questioned the use of masking ~ tape on stainless steel pipe (due to tape' chlorides and the susceptibility of stainless to intergranular stress' corrosion cracking)..
A control procedure was developed in November, 1978, but was not effectively implemented until April,1939. (sNp e Mem, u,d bk. G rro:. )
l In addition to the three examples above, as previously noted major problems were identified with the HVAC contractors quality program in October,1978 and are still not completely corrected, c.
L.'rge inspection backlogs.
,V,
/
Berause of the licensees loss in confidence of the lipe support i
and HVAC contractors quality programs, the licensee has insti-tuted a stopgap measure whereby no hardware is finally accepted until it has been examined by,not only the contractors quality forces, but also the licensees QA representatives. This has resulted'in massive amounts of work which has been accomplished
(.because the crafts have continued to work).but not accepted
==
by quality control, for example, in January,1979 over 2,000 5
quality class I pipe supports had been installed but only 28 had'been accepted.
Si.milarily, the HVAC contractor has reportedly g -
completed 78% of his work with very little (~ 10%) finally accepted.
It is felt that as project: completion approaches there may be a strong tendency to accept 7NErYwhich was done
~
long in the past dueta an overload on quality inspection personnel (ir.spections may tend to become less thorough) or there may b9 a tendency to " analyze" undesirable conditions away.
3.
Poor site records control.
There have been several instances in the past few months where the licensee has been unable to produce quality records' for NRC inspection:
tr.
(1)
In November,1978 the licensee was unable to locate structural welding inspections records in four areas (Contract 206), and electrical receiving inspection records were incomplete j
(Contract 218). -~
(2)
In March,' 1979 the licensee was unable to locate battery and battery rack installation records in three areas (Contract 218).
(3)
In April,1979 the licensee was unable to locate liVAC
'~~i duct veld and support welding inspection records (Contract 216).
l
t.
- =..
.=.::
' " 'i
~
_4 In the majority of the instances where records requested by the -
t NRC have been lost, the licensee reported that the inspections
- would be performed again. This, however, does not address the broader m:.ern of the apparently ineffective control system
~
and the status of other quality records.
4.
Contributing Problems There are several problem; which appear to contribute to th'e per-formance. level of the _ licensee at the WNP-2 site.
Among these are:
/ ' a.
Multitude of site cor. tractors performing quality class I work.
The licensee has _ over 30 contractors and subcontractors per-forming quality class I work onsite.
Each contractor has his own quality program, and his own quality implementing procedures.
With c'nstruction activities at a peak at this stage of con-struct'on there is a significant dilution of effort on the licenst :s site QA staff.
It appears that the licensees site QA staff is assigned lead gj~=
responsiblity for assuring contractor and subcontractor compliance
(
. to contract specification requirements.
s From the NRC perspective it appears that Constiuction Management has not played the major role in requiring contractor compliance
^
to specification requirements.
This is paritcularly true when problem resolution is required (e.g., mechanical, electrical, instrument, and HVAC contractors).
This situation puts additional drains on site QA resources.
c.
Overly complex and over committed procedur_al requirements.
In several'ca'ses it appears the contractors have developed overly complex procedures (mechanical contractors pipe support inspection procedure and document control procedure) and may have committed to codes and standards more stringent than needed T -(e.g. records traceability requirements for certain HVAC While t'is may have been done for simplicity in components).
h writing specifications it unduly complicates procedures, necessitating frequent revisions, with resulting confusion of personnel, and generally detracting from the contractors ability
- 7 "j-to get the job done in the most efficient manner.
As an example the pipe support inspection procedure was revised
_four times in one three-month period and five times in another three-month period.
9
m
,,1
- /;. 4
.c _ y ;( q.
. L.
=-
- ..In' adequate indoctrination of ersonnel. -
c f."
From the nature andamount o.f discrepancies being it., Mfied by the licensees CA program and the NRC it appears the t
's, Sfirst line inssectors, and their supervisors are not fs
. cognizant of their responsibility and accou,tability for tting the work done properly, the first time.
In addition, it is not clear th6t they fully understand that deviati~ons from plans and procedures cannot be tolerated - that if a procedure is not_worbble, it should be improved, rather than violated.
J Inadequate pre-planning and preparation.
As exemplified by problems experienced with pipe sudports,
HVAC,.and instrumentation, the contractors did not adequately ide~ntify the program requirements and generate effectNe control procedures prior to the commencement of quality class i work.
Each of these contractors had ample time to test the eTfectiveness of their quality class' I procedures while they were sti.'l performing quality class II work.
This situation woulc' have ff identified areas where training and procedures were inadequate,
~~
(
. eliminating the need for large amounts of rework.
It is also noted that the licensees programs for assessing the readiness of contractors to perform quality cla'ss I work have not been a s effective as required.
5
'f.
Inadequate feedback of problems to firstline personnel.
7 From the repetative nature of many of the licensees findings it appears that the crafts are not being properly advised of defects found in their work.
The licensee does'not have a routine feedback program which reaches the crafts level.
5.
Actions I
or In th'e cover letter of the most recent inspection report (50-397/
79-04) the licensee has been requested to inform the NRC of the additional steps which have been or will be taken to assure effective implementation of quality requirements at the WNP-2 project.
It is anticipated that a'~ satisfactory response to this r'equest will include reference to st'rong WPPSS management action to achieve immediate improvements regarding the specific and contributing' problems mentioned above.
If improvement is not achieved ibmediately, additional enforcement action may be required; e
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