ML20030D888
| ML20030D888 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/12/1980 |
| From: | Ferguson R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20030D878 | List: |
| References | |
| FOIA-81-199 EA-80-020, EA-80-20, NUDOCS 8109170115 | |
| Download: ML20030D888 (5) | |
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Degulatory Commission
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Attention:
Mr. Victor Stello, Jr.
1 rector Office of Inspection a Enforcement
Subject:
Washington Public Power Supply Sys tem Nuclear Project No. 2, Docket No. 50-397; CPPR-93, QA-80-20; Clarification of Responses to the Notice of Proposed Irrposition of Civil Penalities and to the Notice of Violation
Reference:
1)
WPPS$ Letter Number G02-80-151, dated July 11, 1990 2)
WPPSS Letter Number G02-80-150, dated July ll, 1980 Gentlemen:
Our continuing investigation of the items of noncompliances denoted in the Notice of Violation dated June 17, 1980, has disclosed addi-tional infonnation that we would like to present.
Additionally, dis ussions with NRC Region V personnel indicated that certain items contained in our responses need clarification.
I addresses additional infonnation that is related to our July 11. 1980 lette.r nurr.ber G02-80-151, " Reply to Notice of Proposed Irr. position of Civil Penalities". contains additional information and provides clarification of information related to the July ll,1930 letter number G02-80-150, " Reply to Notice of Violation".
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Very truly yours,
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l-R. L. Ferguson.
Haneging Director l
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ATTACHMENT 1 CLAikIFICATIONOFP.ESPONSESTO NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALITIES The following paragraphs provide additional information related to the July 11 1980 letter number G02-80-151. " Reply to Notice of Proposed Irnposition of civil Penalities",
_ Item I.A_
(Ref:
Pages 2, 3 and 4 of 15 of. Attachment)
We are still investigating the circumstances associated with the failure to r.emplete the plug welds between the tnird end fourth courses on the sacrificial shield wall. We now velieve we over-emphar.ized enD neering review oversight i
during the approval of the RFI ('215-2571, Actust 4,1977) and under-enphasized the contractor's failure to follow contract requirements.
That emphasis was largly due to our focus on why the missing welds were overlooked as opposed to why they were never conpleted.
It is clearer now that the basic problem was the subcontractor failed to follow the fundamental contract specification requirement that the various courses of the sacrificial shield be welded to-gether. Additionally, the subcontractor failed to follow their A/E approved construction procedure and various subcontractor and A/E drawings all of which noted the required slot welds or cautioned that alignment was necessary to allow for slot welds.
The referenced RFI appears not to be the focus of the error.
It requested that the A/E Engineering group approve the use of pemanent steel shims. The RFI was approved without repeating the existing specification requirenent for slot welds. This RFI did not relcase the contractor from rasponsibility for welding the c.ourses together.
The ability of the A/E Engineers to identify the possibility of missing-wolds was obscured by erroneous verbal and written
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information supplied to the A/E by the subcontractor, Item I.B.l.
(Ref:
Pages 5 and 6 of 15 of Attachment)
The Supply System response was ba ;d in part on erroneous reference to our Quality Assurance Program Description.
We stated that the program description did not require that the Owner or the Engineer review and approve special pro-cess procedures such as " Ultrasonic Testing".
This statement was in error in that paragraph D.2.8.9, " Control of Special Processes", does require " review and approval by Burns and Roe",
The remainder of the argument is correct, in that, the subject procedure was
" tentatively enoroved" on June 2-3. 1976.
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.r ATTACHMENT _2 CLARIFICATION OF RESPONSES TO REPLY T0, NOTICE OF VIOLATION
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The following paragraphs provide additional infonnation and clarification of infor
- mation related to the July 11, 1980 letter nucber G02-00-150, " Reply to Uctice of Viol a tion".
Item I.A (Ref:
Page 1 of 39 of Attachment) 1 The roct cause for the noncompliance was failure by the contractor to iripic-ment contract procedure and drawing requiremerits.
The second line surveil-lance also failed to detect the incomplete welds largely as a result of the l
erroneous verbal and written i formation supplied by the subcontractor.
I Item I.D.1 (Ref:
Page 4 of 39 of Attachwant)
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Since certain aspects of our answer to the Hotice of Proposed Imposition of Civil Penalties was partially in error, we include the following for clarifi-cation:
.i-Reason for Noncompliance The subject subcontractor ultrasonic pr$cedure was reviewed and tentatively approved by Burns and Roe on June 2.1976 but not reviewed or apprend by the contractor (flovce and Crail/GEP.I) until July 22. 1976. The sub-contractor did not kplement the contract requirement for opproval of the procedure by the contractor before its use.
Dovce and Crail/CERI vendor surveilTance failed,to detect the use of the procedure before its approval.
Corrective _ Steps Taken and Results Achieved The reinspection plan was developed for accessible portions of the secrl-ficiel shield.
The reinspections included visual, ultrAsenic testing and magnetic particle testing.
The results of these reinspections and the associated technical evaluations of overall shield wall adequacy have been submitted to the NRC in a separate report in response to the NRC's i.=ediate, action letter dated November 21, 1979.
Corrective Steps Which Will Be Taken To Avoid Further items of Encompl1 a n_c_c, e
or other work associated with WNP-2. our letter in response to your '.
r June 17,1980,10 CFR 50.54(f) request addressed this item. This 1stter b
was submitted on July 17, 1980.
In addition, our response to the NRC L
Region V annual appraisal will address corrective actions taken and i
planned to be taken to correct the underlying cause of the noncenpliance.
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Date Full Compliance Achieved or Scheduled t_o Be Achieved The date of full complianca cannot be determined until the NRC review e
of the " Sacrificial Shield Wall Technical Evaluation Report" (submitted '/
separately) is completed.
We will infom you of our scheduled ccmpletion date following NRC approval of the Technical Evaluation Report.
Item II.A.4 (Ref:
Page 23 of 39 of Attachment)
This noncompliance item dealt with the use of localized heat to straighten certain pipe whip restraints.
Our review of corrective actions taken and planned to be taken to correct the deficiency disclosed that we should also describe a plan to physically examine the restraint materials. A selection of pipe whip restraints..ill be examined roetallurgically to determine if the use of localized heat had adversely affected their physical prop::rties. The results of these examinations ytll be available for review by the Renton V Inspectors.
Discussions with NRC Region V personnel and our further investigations have allowed us to more clearly identify the " root causes" of some of the identified items of noncom;>11ance.
. Item I.C.1 (Ref:
Page 8 of 39 of Atcachment)
As stated in the wording of the. noncompliance, the contract specification required that the AWS Code be met.
The subcontractor QA program failed in that the repair instructions / procedures did not fully address the code require-ments for liDE used for crack definition.
Bovce and Crail/GERI and Burns and Roe failed to determine that the repair instruction did not specifically in-clude the code requiremencs.
Item I.C _2_
(Ref:
Page 9 of 39 of Attachment)
The " root cause" of this item is similar to Item I.C.l. in that procedure preparation, review-snd approval cycle failed to disclose that all code requirements had not been incorporated into the erection procedure.
Item _I.C.3 (Ref:
Fage 10 of 39 of Attachment)
The " root cause" of this item is the failure to provide procedures for acti-
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vities affecting quality.
The contractor's vendor surveillan:6 01so failed to disclose that quality-affecting activities were being accomplished at the subcontractor's shop without approved procedures.
. Item I.D.2 (Ref:
Page 14,0f 39 of Attachment)
The " root cause" of this noncompliance is failure of (1) the subcontractor's NDE personnel to follow procedure, (2) the subcontractor Quality Assurance record revicw to disclose these errors, and (3) the vendor surveillance pro-vided by Dovee and Crail/GERI to discover the errors.
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Item ll.A.l (Ref:, Page 18 of 39 of Atta$hment), _
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The " root cause" of this item is failure of' the contractor to fully imple-ment all contract requirements.. The vendor surveillance sampling program I
c1so failed to identify the failure to provide all required procedures be-fore start of an activity.
Item II_. A.2 (Ref:
Page 20 of 39 of Attachment)
The " root cause" of this item is failure of the contractor to include all contract, specification and procedurc record requirements in the NDE rvport fonn. The A/E's procedure review program also failed to disclose the miss-ing documentation requirements.
I thin I I.B'. 2 Item I'l.B.3 (Ref: Page 28 of 39 of Attachment)
Ref:
(
Page 30 of 39 of Attachinent)
_ Item II.8.4 (Ref:
Page 31 of 39 of Attachment) f The " root cause" of these items of noncompliance are the same. The contrac-tor's training program failed to fully inform NDE personnel of documentation controls and requirements.
The contractor's record review, as well es the Burns and Roe vendor surveillance sampling program failed to disclose these
, items. }iowever, the proiect Quality Assurance records review program at the site did detect these deficiencics.
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Item III.A.2 (Ref:
Page 35 of 39 of Attachment)
The "rnot cause" of the ;.gid strut being tariented 90 degrees from the con-figuration on the drasing is that the fitter made changes to the configura-tion of the hanger without the required approval.
The QA program requires that changes are reviewed in accordance with design control procedares.
Item III.A.3_
(Ref:
Page 37 of 39 of Attachment)
The " root cause" of "this item is the failure to complete the inspection form as required by procedu:e and the failure of document review to disclose the e
missing requirement.
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