ML20030D903
| ML20030D903 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/17/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20030D878 | List: |
| References | |
| FOIA-81-199 NUDOCS 8109170133 | |
| Download: ML20030D903 (13) | |
Text
i t
(
s 2 "-
~'
gn/roCWlJ APPENDIX A Washington Public Power Supply System E~
9 P. O. Box 968
(
Richland, Washington 99352
~7J)J U D -
2 Constration Pennit No. CPPR-93 NOTICE OF VIOLATION Based on the results of NRC investigation conducted betwen November 27, 1979 and February 28, 1980, it appears that certain of your activiMas were not con-ducted in full compliance with conditions of your NRC Facility License No. CPPR-93, 10 CFR 50, Appendix B, Criterion VII, states, in part, that " Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractnrs, conform to the pro-curement documents...The effectiveness of the control of guality by contractors and subcontractors shcil be assessed by the applicant or.asignee at intervals consistent with the importance, complexity, and quantity of the product or services."
One of the measures to control quality of contractor products is delineated in Paragraph 0.2.5 of the WPPSS Quality Assurance Program documented in the PSAR which states, in part, that "...All project contractors for nuclear related portions of the plant will be required to have a Quality Assurance Pmgram which shall be in accordance with the requirements of Appendix B,10 CFR 50...."
Further, Paragraph 0.2.3 of the PSAR descri' as three levels of control in the Quality Assurance Program.
The first level requires mnufacturers and site con-tractors to have a quality control pmgram and inspections which demonstrate the final end product has the specified degree of quality.
The sccor.d level, per-formed by the Architect-Engineer / Construction Manager (Burns & Roe), requires quality assurance surveillance of individual manufacturer's and site contractor's quality control and inspection programs to insure that the design and quality requirements are in fact being met.
The third level is performed by the WPPSS Supervising QA Engineer, assisted by Burns & Roe, as appropriate.
This level includes reviews of specifications and other requirement documents furnished by the contractors to insure that the necessary quality requirements have been incorporated in these documents and audits of manufacturing and construction activities to insure that the quality programs of the contractors are actually -
functioning as required.
failed to assure that the pertinent
, The implementation of the above measures requirements of 10 CFR 50 Appendix B, were met by contractors as indicated belo'w.
'I.
Items of fbncompliance _Rel_ating 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 accom-plished in accordance with these instructions, procedures, or drawings.
r Instructions, procedures, or drawings shall include appropriate quant-itative or qualitative acceptance criteria for determining that impor-tant activities have been satisfactorily accomplished."
-199 DR o
c-
L.
(.
l
. Paragraph 0.2.5.5 of the WPPSS Qualit.y Assurance Program documented in the PSAR 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 accordance with these instructions, procedures, or drawings...."
1.
The erection of the reactor building sacrificial shield wall is arescribed, in part,.by drawing No. 2008-5836 Revision 2, Note iN, 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 in place at the interface of the bottom seg-ment ring beam and the top of the box ring beam.
These shims prevent several slot welds from joining the ring beams.
This Violation resulted in the as built structure teing incapable of perfoming its intended safety function during design basis earthnake conditions and certain postulated pipe break accidents (Civil Penalty - $5000.00).
2.
The fabrication, erection, and testing of the sacrificial shield is prescribed in part by WPPSS Contract Specification No. 2808-215.
Appendix D of this specification, entitled " Technical Documentation and Procedure Requirements" states, in part, that
... Document (including test procedures) is to be submitted for l
approval and must be approved or approved as noted by owner before affected work can proceed... "
Contrary to the above requirements, ultrasonic testing of the weld joints listed below were performed before an owner-approved procedure was provided Component Weld _ Joint Date Ring beam 113b Joints 23, 24 June 17, 1976 l
113c Joints 31, 32 114c Joints 23, 24 Box Column 29b Joints 21-28 June 16, 1976 l
l 29a Joints 1-8 I
p Weld Maps W45 Joints 9-10 July 24,1976 W21 Joints 1-6, 8-10, 12, 13 W22 Joints 1-4, 6-8, 10, 11 l-i 12, 13, 167 G
4.
}
t
\\
~
. Component _
Weld Joint Date Weld Map H22 Joints 15, 16, 22, 132 July 24, 1976 140, 30, 168, 155, 32, 33, 35, 37, 166 Electro-Slag X-100 June 2, 1976 Joiats X-102 The contractor's first approved ultrasonic test procedure (Quality
(
Control Procedure 8.0, Rev.1. " Ultrasonic Testing") was approved by the owner (owner's agent) on September-27, 1976 This noncon-forming condition was not identified nor were the weld joints retested after an approved procedure was provided.
This is an Infraction (Civil Penalty - $3000.00).
3 The fabrication of the sacrificial shield wall is prescribed in part, by WPPSS Contract Specification No. 2808-215. This docu-ment specifies that welding shall be in accordance with the AWS Structural Welding Code D.1.1-1974.
Paragraph 3.7.2.4 of the Structural Welding Code states, in part.
that for the repair of cracks in welds or base metal, "...Ascer-tain the extent of the crack by use of acid etching, magnetic particle testing or other equally positive means: remove the crack and sound metal 2 inches beyond each end of the crack, and reweld...."
Contrary to the above requirements, repair instructions and l
completion signatures dispositioning " incomplete / Rejection Tags" Nos. 5256, 5325, 5412, 6055, 6056, 6058, 6059, 5443, 5444, 544F, l
5446, and 5447 demonstrate that the repairs made to cracks in L
shield wall subassemblies during the period of April 1976 to L
April 1977 were made without using acid etching, magnetic particle l
testing, or other positive neans to define the cracks, and sound metal 2 inches beyond each end of the cracks was not removed as
~,
required by the code.
.This is an Infraction (Civil Penalty - $3000.00).,
l=
4.
The fabrication of the sacrificial shield wall is prescribed in part, by WPPSS Contract Specification No. 2803-215. This docu-ment specifies that welding shall be in accordance with the AWS.
Structural Welding Code 0.1.1-1974.
~
Paragraph 3.4.3 of the Structural Welding Code states, in part,
l that "...The contractor shall develop weld sequences which...
will produce members and structures meeting the quality require-ments specified.
These sequences and any revision necessary in the course of the work shall be sent for information and connent' to the engineer...."
F a
L:
t j
Contrary to the above requirements, as of December 7,1979 the weld sequences developed by the contractor and used during fabrication of the shield were not submitted to the engineer (Burns & Roe, Inc.). These weld sequences are delineated in a document, entitled, " Sacrificial Shield Wall Assembly Procedure" which was an informal document, not signed or controlled by the contractor.
This is an Infraction (Civil Penalty - $3000.00).
5.
The fabrication, erection, and testing of the sacrificial shield wall is prescribed in part by WPPSS Contract Specification No.
2808-215 which requires that nondestructive testing personnel be qualified in accordance with the requireronts of the American Society for Nondestructive Testing Reconnanded Practice No.
SNT-TC-1A (Third Edition).
SNT-TC-1A specifies that individuals who read and interpret indi-cations (test results) shall be certified NDT Level II or III and that the certification is not transferable between employers.
For certification, as a NDT Level II, an individual must be admin-istered a general written examination (covering basic test prin-ciples); a specific written examination (covering equipment, operating procedures, and techniques); and a practical examination (to demonstrate operation of equipment and analysis of resultant information).
The practical examination should include at least 10 different check points.
Further, an individual certified as a' NDT Level III shall be responsible for conducting and grading examinations of NDT Level I and II personnel.
Contrary to the above requirements:
1~
a.
An individual, who was never qualified by the contractor, performed nondestructive ultrasonic testing on the sacrificial shield wall plates Nos. bS6 and fS6 on June 2, 1976.
p.
b.
An individual performed ultrasonic testing (UT) on the sac-rificial shield wall ring beam 113b, welds 23/24 on June 17, 1976; ring beam 1146, welds 15/16 on June 17,1976; sub-assembly 56b for segment 22A, welds 212 to 235 on June 17, 1976; box column 29b, welds 21 to 28 on June 16,1976; ring
(
3 dwg 56, welds 100 and 102 on June 2,1976; ring 8, pc 252c, l
weld 115 on August 4,1977, and others without having taken l
w a practical examination which was in accordance with SNT-TC-1A.
l Specifically, no check points were defined or applied to the j
examination as recuired by SNT-TC-1A, and the examination 3
document did not remonstrate that an individual certified as.'
l a NDT Level III conducted or graded the examination.
t l
This is an Infraction (Civil Penalty - $3000.00).
(
l e
t b
b.......
.k
. B.
10 CFR 50, Appendix B, Cr'iterion V, states that " Activities affectin quality shall be prescribed by documented instmctions, procedures, g 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 appro-priate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Paragraph D.2.5.5 of the WPPSS Quality Assurance Program documented in the PSAR states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances...The activity may be prescribed in job specifications, work instructions, shop construction drawings, job tickets, planning sheets, operating or procedure manuals, test procedures, or any other type of written form, provided that the activ-ity is adequately described.
Quantitative criteria, such as dimen-sions, tolerances, and operating limits...shall be specified...."
WPPSS Contract Specification No. 2808-215 for the sacrificial shield wall specifies that work shall be done in accordance with the AWS Struc-tural Welding Code D.1.1-1974 Paragraph 3.7.3 of this code, states, in part, that "... Members distorted by walding shall be straightened by mechanical means or by carefully supervised application of a limited amunt of localized heat.
The temperature of the heated areas as measured by approved methods shall not exceed..1200F...."
~
Contrary to the above requirements, no documented instructions, pro-cedures, or drawings were provided to control the application of 1rcalized heat during the straightening of each segment of sacrificial shield wall ring beam No. 3 and segment 2A of ring beam No. 2, and other shield wall components as documented on Manufacturing Order Nos.
000904, 000913, 000916, 1193, 1666 and others during 1976.
Control of the maximum temperatures in the heated areas was not assured nor is there documentation of the methods used to measure the temperature or t.he actual temperatures reached during this activity.
Temperature con-trol during N heat straightening process is important in assuring that the as bui physical pmperties of the material.
l This is an Infraction (Civil Penalty - $3000.00).
C.
10 CFR 50, Appendix B, Criterion XVII, states that " Sufficient records shall be maintained to furnish evidence of activities affecting qual-ity.
The records shall include at least the following: operating logs and the results of reviews, inspections, tests, audits, monitor-ing of work performance, and mterials analyses.
The records shall also include closely related data such as qualifications of personnel, procedures, and equipment.
Inspection and test records shall, as a L.inimum, identify the inspector or data recorder, the type of observa-tion, the results, the acceptability, and the action taken in connec-tion with any deficiencies noted.
Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention.
e such as duration, location and assigned responsibility."
A
4
[
I.
J
_ Paragraph D.3.4.17 of the WPPSS Quality Assurance Program as documented in the PSAR states in part, that " Sufficient records will be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality...The Records include, as a minimum, the results of reviews, inspections, tests, audits, monitor-ing of work performance... Inspection and test records will, as a mini-cum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Required records will be identifiable and retrievable..."
(
Contrary to the above requireroents:
a.
On January 24, 1980, quality records were not retrievable which identify the individuals who performed many of the visual inspece tions on the shield wall, as indicated by the following examples:
15 I6 (1) Shield wall manufactuyng orders for pieces a
, 15c, d g 14 t 13 15V and b (no serial numbers had been recorded o$ thesb ra,nufacturing orders) documented inspections per-formed by inspector No. 7 between January 16,1976 and March 1,1976 The contractor has no records available to provide the identity of this individual.
(2) Shield wall Manufacturing Orders 000515, 000631, 1606, 1249, 1263, and 1569 document inspections by inspector No. 4 in May and June 1976.
The contractor has no records available to provide the ident.ity of this individual.
(3) Shield wall Manufactu. ing Orders 2000, 2002, 2020,1866 and 1945 document inspections by inspector No. 6 in August 1976 The contractor has no records available to provide the identity of this individual, The lack of the above records does not enable verification that u-the inspections were perfonned by qualified personnel.
b.
On January 23, 1980, information contained in quality records was inconsistent and did not accurately reflect activities per-formed on the shield wall as indicated by the following examples:
(1) Shield wall ultrasonic test report for piece No.113/78 is l
not dated and results of testing are not indicated.
l (2) Shield wall Manufacturing order No. 000917 indicates that welds 1-4 on drawing (75 were perfonned using welding prece--
f-dure No. 0001-13-06 the electmslag welding process); the weld map for these welds indicates the welds were made L
using procedure No. 0001-01-10 (the shielded metal arc weld-
- 4...
ing process).
f 6
gee
[...
(
(
(3) Two shield wall weld maps Nos. W256 exist.
One map indi-cates welding electrode serial Nos. A383ER/029092 were used to make welds 4, 5 and 6; the second map indicates electrodes Nos. A383ER/036084 were used to make the same welds.
The above noted cuissions and inconsistencies resulted in records which do not provide assurance that these activities were satisfactorily performed.
This is a Deficiency (Civil Penalty - $1000.00).
II.
Items of Noncompliance Relating to Pipe Whip Restraints 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 end shall be accnm-plished in accordance with these instructions, procedures, or drawings, Instructions, procedures, or drawings shall include appropriate quant-itative or qualitative acceptance criteria for determining that impor-tant activities have been satisfactorily accomplished."
Paragraph D.2.5.5 of the WPPSS Quality Assurance Program documented in the PSAR 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 accordance with these instructions, procedures, or drawings..."
1.
The fabrication of safety related pipe whip restraints is pre-scribed in part by WPPSS Contract Specification No. 2808-90.
Division 5, Section 5A, " Technical Specifications for Pipe !! hip Restraints," Paragraph 3.8.2. of the contract specification states, in part, that "... Contractor shall submit to owner...all quality assurance procedures required... contractor shall not proceed with the affected work until its... procedures have been approved by the ormer."
Contrary to the above requirements, ultrasenic testing was per-fonned on pipe whip restraints Nos. PWS 30-5, PWS 27-17, and PWS 6-1 in September and October 1976 before owner-approved pro -
cedures ware provided.
Contractor procedures for this work (QCP 8.0, Revision 0, " Nondestructive Testing Procedure for Ultra-sonic Inspection;" QCp 8.2, Revision 0, " Qualification and Certi-ficat?on Procedure for Nondestructive Test Personnel;" and QCP 8.4, Revision 0, " Nondestructive Test Qualification Criteria")
were approved by the owner (owner's agent) on November 8,1976.
This nonconfonning condition was not identified nor were the a
i
~
weld joints retested of ter on opproved procedure was provided.
This is an Infraction (Civil Penalty - $3000.00).
N pe==
A
l t
1 t
.. ~.
8
. 2.
The testing of safety related pipe' whip restraints is prescribed in part by Contractor Procedure No. QCP 8.0, Revision 0, "Non-destructive Testing Procedure for Ultrasonic Inspection." Pa ra-graph 4.4 of this Procedure, states, in part, that "...Before the angle beam examination, the area of the base material through which sound will travel in angic beam examination shall be com-pletely scanned with a straight beam search unit to detect any reflectors which might affect the interpretation of angle beam resul ts.... "
s Contrary to the above requirements, information was unavailable to indicate that straight beam examination was accomplished during ultrasonic examination of safety related pipe whip re-straints Nos. PWS 315-5, 315-6, 315-7 and 315-8.
The ultrasonic test records for these restraints, dated June 21, 1978, indicate that only angle beam examinatien was. performed.
This is an infraction (Civil Penalty - $3000.00).
3.
The fabrication and testing of safety related pipe whip restraints is prescribed in part by WPPSS Contract Specification No. 2808-90 which requires that nondestructive testing personnel be qualified in accordance with the requirements of the American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A (Third Edition).
P f
SNT-TC-1A specifies that individuals who read and interpret indi-cations (test results) shall be certified NDT Level II or III and that the certification is not transferable between employers.
For certification as a NDT Level II, an individual must be admin-r istered a general written examination (covering basic test prin-l ciples); a specific written examination (covering equipment, oper-ating procedures, and techniques); a,d a practical examination (to deconstrate operation of equipment and analysis of resultant
(
infornation).
Q ~.
Contrary to the above requirements:
An individual, who was neve'r qualified by the contractor, a.
performed the required noncestructive magnetic particle testing on pipe whip restraints Nos. PWS 27-1, 27-5, 28-1, 28-2, 31-4, 32-3 and 33-4 Quality records for these tests are dated August 17, 1976, August 17, 1976, August 17, 1976, i
August 17, 1976, August 19, 1976, Augus t 19, 1976 and August 25, 1976, respectively.
I
'l -
t _
(
~
. t b.
An individual, who had not taken a " specific" written exami-nation for mgnetic particle testing as required by SNT-TC-1A, performed the required mgnetic particle testing on pipe whip restraints PWS 3G-8 on August 4,1976, PWS 36-12 and PWS
~
36-13 on August 11, 1976, and others.
This is an Infraction (Civil Penalty - $3000.00).
B.
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 accom-plished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quant-itative or qualitative acceptance criteria for determining that impor -
tant activities have been satisfactorily accomplished."
Param aph 0.2.5.5 of the WPPSS Quality Assurance Program documented in the PSAR states in part, " Activities affecting quality shall be pre-scribed by documanted instructions, 3rocedures, or drawings, of a type appropriate to the circumstances... Tie activity may be prescribed in job specifications, work instructions, shop construction drawings, job tickets, planning sheets, operating or procedure manuals, test procedures, or any other type of written form, provided that the activity is adequately described.
Quantitative criteria, such as dimensions, tolerances, and operating limits...shall be specified....".
WPPSS Contract Specification No. 28G8-90 for safety related pipe whip restraints specifies that work shall be done in accordance with the AWS Structural Welding Code D.I.1-1974. Paragraph 3.7.3 of this code, states, in part, that "... Members distorted by welding shall be straightened by mechanical means or by carefully supervised appli-cation of a limited amount of localized heat.
The temperature of the heated areas as measured by approved methods shall not exceed..1200F...."
Contrary to the above requirements, no documented instructions, proce-dures, or drawings were provided to control the application of local-ized heat during the straightenir.g of pipe whip restraint subassemblies as documented on Manufacturing Order Nos. 0710, 0726, 0730, 0735 and 0736 during August and September 1976 Control of the maximum temper-s atures of the heated areas was not assured nor is there documentation of the methods used to measure the temperatures or the actual tempar-atures reached during the activity. Temperature control during the heat straightening process is important in assuring the as built physical properties of the material.
This is an Infraction (Civil Penalty - $3000.00).
t
%. *f. ?
p.-
+
~ q. -.-..
_ _.. a....
. -- -- -t
{ :.;
l-l C.
10 CFR 50, Appendix B, Criterion XVII, states that " Sufficient records shall be maintained to furnish evidence of activities affecting qual-i ty.
The records shall include at least the following: operating logs and the results of reviews, inspections, tests, audits, monitor-ing of work performance, and materials analyses.
The records shall also include closely related data such as qualifications of personnel, procedures, and equipment.
Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observa-tion, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Records shall be identifiable and re-trievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, s
such as duration, location, and assigned responsibility."
Paragraph D.3.4.17 of the WPPSS Quality Assurance Program as documented in the PSAR states in part, that " Sufficient records will be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality...The Records include, as a minimum, the results of reviews, inspections, tests, audits, monitor-tng of work perfonnance... Inspection and test records will, as a mini-wm, identify the inspector or data recorder, the type of observation.
the results, the acceptability, and the action taken in connection with any deficiencies noted.
Nguired records will be identifiable and retrievable..."
(
Contrary to the above requirements:
a.
On January 24, 1980, quality records were not retrievable which identify the individuals who performed many of the visual inspec-tions on pipe whip restraints as indicated by the following T.
examples:
(1) Pipe whip restraint Manufacturing Order No. 0457 for PWS 53-15 documents inspections performed by inspector No. 6 on August 13, 1976 The contractor has no records available to provide the identity of this individual.
(2) Manufacturing Orders 0213 and 0686 for restraints PWS 53-1 and 54-14 document inspections perfonned by an inspector No.
9 on July 21-22, 1976. The contractor has no records avail-able to provide the identity of this individual.
The lack of the above records does not enable verification that the inspections were performed by qualified personnel.
k b.
On January 23, 1980, information contained in quality records was inconsistent and did not accurately reflect activities performed
~ -
on safety-related pipe whip restraints as indicated by the follow-ing examples:-
S
- 4_._-_.
~
~
. (1) Magnetic particle test reports for PWS 36-23, 52-8, 36-1, 35-58, 34-5B, and 32-7 contain data and inspection results written by one inspector and bear the photocopied signature of a different inspector (the two individuals reported that they did not collaborate on the inspections involved).
(2) Ultrasonic test reports for restraints Nos. PWS 1-1 and 2-1 reported that the ultmsonic testing was pe'rfomed on October 5,1976 after post weld heat treatment (PWHT); the manufacturing orders for the same restraints recorded PWHT as occurring on October 6,1976.
c.
Manufacturing Order No. 0750 for restraint No. PWS 53-14 documents that inspector No. 5 performed magnetic particle testing on the restraint on September 24, 1976, whereas the test report for that restraint bears the photocopies signature of a different inspector.
d.
Magnetic particle inspection report for restraint PWS 36-9 reports that the testing was performed on welds 6 and e on August 4,1976; hcwever, the record bears the photocopied signature of an inspector who was not hired until August 16, 1976.
The above noted inconsistencies has resulted in records which do not provide assurance that these activities were satisfactorily performed.
This is a Deficiency (Civil Penalty - $1000.00).
III. Itcens___of Noncompliance Relating to Recent Construction Activities A.
10 CFR 50, Appendix B, criterton V, states that " Activities affecting cuality shall be prescribed by documented instructions, procedures, or c:rawings of a type appropriate to the circumstances and shall be acccm-plished in accordance with these instmettons, procedures, or drawings.
Instructions, procedures, or drawings shall include approp'riate quant-itative or qualitative acceptance criteria for determining that impor-tant activities have been satisfactorily accomplished."
Paragraph D.2.5.5 of the WPPSS Quality Assurance Program documented in l
the PSAR states, in part, that " Activities affecting quality shall be l
prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished ir.
accordance with these instructions, procedures, or drawings...."
1.
The cont s1 of welding filler material, a quality affecting activity, is prescribed for the prime site piping contractor (Contract Specification No. 2808-215) in his Work Procedure No. 1, Revision 20, " Issuing and Control of Weld Filler Material".
Paragraph 5.8 of this procedure, states, in part. that "... Porta-ble rod ovens shall be connected to a reliable electric soun:e
~,
during the shift.
The pink copy of the Fom NF-69 mus". remain with the rod until the rod is consumed or restocked...."
c...
Y I.i t.
m
Contrary to the above requirements:
a.
On February 25, 1980 in reactor building room 3C at clovation 548, the subject contractor had a portable rod oven containing Type E-7018 low hydrogen wald rod which was open and not connected to a power source.
The weld rod was at ambient temperature, and the welder was not in the area, b.
During a previous inspection on January 16, 1980, two unused coated electroder and nne partial length coated electrode were lying loose, unattended and not contained in a portable oven at elevation 540 in the reactor containment building. Welding in this area was under the control of the subject contractor. The filler material withdrawal form NF-69 was not in the vicinity of the electrodes.
c.
On January 17, 1980, six unused Type 7018 coated electrodes were similarly lying loose at elevation 560 in the reactor contain-ment building.
The filler metal withdrawal Form NF-69 was not in the vicinity of the electrodes.
This is an Infractior, (Civil Penalty - $3000.00).
~
2.
The fabrication and inspection of safety related pipe hangers is prescribed in part by the prime site piping contractor's instruc-tions delineated in Quality Control Procedure Number 24, Revision 8 (entitled " Hanger Inspection - Traceable Systems". QCP-24) and
~
Pmject Directive No. 75 Revision 4. (entitled " Hanger Engineer-ing Standards". PD-75).
Paragraph 10.2(A) of QCP-24 states, in part, " Visually inspect all welds... Held size less than shown on as-buil t is unacceptable.... " Paragraph 7.5 of PD-75 states, in part, that "The configuration of supports shall be in accordance *
^
with the as-built hanger detail..." Paragraph 10.1.2 reiterates that " Unacceptable conditions are weld size less than shown on as-buil t.... "
1 L-Contrary to the above requirements, on February 26, 1980, safety l
related pipe hanger No. HPCS-48 had received quality control inspection by the subject contractor and was considered accepta-ble, yet the hanger had one fillet weld that was 1/16 inch under-size, and a rigid strut and its mounting bracket were oriented 90 degrees from the configuration shown on the as-built drawing.
This is an Infraction (Civil Penalty - $3000.00).
3.
The requirements for designating inspection requirements and docu-i rmnting inspections for safety related pipe supports are prescribed
(
in part by t.he prime site piping contractor's instructions delin-5 cated in Pmject Directive Number 75, Revision 4 (entitled " Hanger Engineering Standards", PD-75) and Quality Control Procedure Number 24 Revision 8 (entitled "lfanger Inspection - Traceable Systems",
m' y
n.
c c
3
.a
. 7 Paragraph 5.3 of PD-75 states, in part, that "Enginear-ing shall indicate the HDE...and visual ins?ection requ QCP-24).
traceable systems."
ifies magnetic particle (MT) or liquid penetrant (PT) examinatio of ASME Section III, Class II,. attachment welds to pressure par Paragraph 10.2(A) of QCP-24 states, in part, " Visua J
that "If the welds are acceptable... initial, stamp and date the all welds..."
Assure that all NDE requirments applicabic box on the NF-6A.and any A.I. ' Hold' point have 26, 1980, for Contrary to the above requirements, on February E
pipe support No. LPCS-12, engineering had not indicated th and visual inspection requirements for lug weld number 6 on p support LPCS-12 nor had a quality control i-for this weld (other quality records, howaver, indicated that some NDE had Ocen performed on the weld).
This is a Deficiency (Civil Penalty - $1000.00).
The requirements for protecting safety related instrumen 4.
are proccr%od, in part. hy tha Procedura CP208 which states under General Maintenance Re ments,aat, "... covers, caps, plugs and other closures l
trainuined intact.... "
coverings, shrouds, local scaling, heating methods and mech cleaning shall be employed to keep the structure as clean an dry as possible...."
28, 1980 safety-Contrary to the above requirements, on February which had been disc.nnracted with the end the internals of the system.
The f:!h-c to properly cover, cap, or plug safety-related instrument tubing was cited previousl This is s.. Ir.fr::tica.
79-16.
an item of noncompliance in IE Inspection Report No. 50-39 (Civil Penalty - $4000.00).
tion 2.201 of This Notice of Violation is sont pursuant to the provistor.s of Sec d
l Regulations.
the NRC's " Rules of Practice," Part 2. Title 10, Code of Fe era i
to The Washington Public Power Supply System is hereby required t itten state-this office within twenty days of the receipt of this Notice, a writem of non ment or explanation in reply, including for each (2) corrective steps which will be taken to avoid f f noncompliance; and (3) the date when full compliance will be achieved.
3
/
e
- _, L..... '.
- - - i - -
(
g
\\
U. S. NUCLEAR REGULATORY COMISS1ON 0FFICE OF INSPECTION AND ENFORCEMErlT REGION Y O h..,...,.
.3..-.;
.j-
.y.,
-.n-,...
t'
- i. C-
'.. Ie's 'T. -
Report Nd; '50-397/80-89 67.%' :. ':;
5...'
- . x. - i.-
.. : a:, m.,.-:> ag: : ;.. e.
Docket No.'-50-397
'MM- ' License No.' CPPR-93
~ L y 12..i
~
~
. -- y. ;
\\. :-. _
1.icensee: Washington.Public Power Supply System
\\.
P. O. Box 968 Richland, Washington 99352
~..
Facility Nace:
Washington Nuclear Project No. 2 (WNP-2)
~
Investigation at:
WNP-2 Site, Benton County, WA; Seattle, WA and environs; Tigard, Oregon Investigation conducted:
November 27-30; December 5-7,'12-14, 1979; Jan. 9-11, 22-25, 29-Feb. 1, Feb. 11-14, 25-28, 1980.
Inspectors :
~
efg 4. y ].2 3
- i. W. Bishop, Reactor Inspector.
Date Signed
[DTP Haist, Reactor Inspector
~Date Signed Date Signed W. J. Wagner,. Reactor Inspector ben C. Shackleton Jr., Investigator
~Date Signed
- N' Approved By:\\g Ronald C. Haynes, Chief, Projects Sectic.i Date Signed Reactor Construction and Engineering Branch Sumary:
~
Investication conducted between November 27, 1979 and February 28, 1980 Report No. 50- 397760~~62) 1 Areas Investiaated: kon-routine unannounced investigation by regional based inspectors and an inve'stigjlto reported photocopying of inspectors signa-tures on pipe whip.inspec9on records and other record irregularities. The iny~estigation subsequentl expanded to the sa'crificial shield wall and included examinations of personne qualifications, records and records generation prac tices, fabrication and i spection procedures, completed work activities.
J.-
cd lhe investigation invol"ed 294 hours0.0034 days <br />0.0817 hours <br />4.861111e-4 weeks <br />1.11867e-4 months <br /> by three NRC inspectors and an NRC gf investigator.
.fQ 3.hf 0
y-sta-
\\M M.6 g C o v e v-
. ?..
A 1nnes
-:.=' A3.W L_. :'
+
-