ML20038A673
| ML20038A673 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 08/19/1981 |
| From: | Leddick R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Crews J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20038A671 | List: |
| References | |
| GO3-81-2384, NUDOCS 8111160144 | |
| Download: ML20038A673 (8) | |
Text
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y-Washington Public Power Supply System Box 1223 Elma Washington 98541 (206)482-4428 August 19, 1981 G03-81-2384
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Nuclear Regulatory Commission, Region V Suite 202, Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California 94596 i
Attention:
Mr. J. L. Crews, Acting Director Division of Resident, Reactor Projects and Engineering Inspection
Dear Mr. Crews:
Subject:
PROJECT NOS. 3 AND 5 NRC INSPECTION OF WNP-3 AND WNP-5 DOCKET NilMBERS 50-508 AND 50-509
References:
- 1) Letter, J. L. Crews to R. S. Leddick, dated July 20, 1981.
- 2) Letter, D. F. Knuth to all AEC Licensees,
" Criterion for Determining Enforcement Action and Categories of Noncompliance,"
dated December 13, 1974.
This letter is in response to your letter of July 20, 1981, which dis-cussed the results of the inspection conducted April 13 through April 23, 1981 of activities authorized by Nuclear Regulatory Commission Construction Permit Numbers CPPR-154 and CPPR-155.
The letter identi-fied five items of Noncompliance and four significant observations categorized in accordance with Reference 2 and required the Supply Sys-tem to provide a response to these items.
The specific Nuclear Regulatory Commission findings, as stated in your letter, and the Supply System responses are provided in Attachment I to this letter.
As the subjects discussed in Appendix B and the detailed report are much more complex, the Supply System will assess these concerns and provide a response to the NRC by October 30, 1981, stating actions taken, actions planned and an anticipated completion date.
f111160144811110 R ADOCK 05000508 G
PDR E$l' /C7
r Nuclear Regulatory Commission August 19, 1981 Attention: Mr. J. L. Crews G03-81-2384 Page Two Should you have any questions or desire further information, please feel free to contact me directly.
Very truly yours,
' ddda l R.
. Leddick Program Director, WNP-3/5 Attachment l
cc:
J. A. Adams - PP&L
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D. Smithpeter - BPA Ebasco - New York i
j UNP-3/5 Files - Richland i
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r R. S. LEDDICK, Deing first d u l y s v.o rn, aep"se: and says:
That he is the Program Director, WNP- /5, for N.!T.5HINGTON PilBLIC POWER SUPPLY SYSTUI, the applicant herein; tha t he is euthorized to submit the fore-going on behalf of said applicant; tnat he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge.
DATED
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, 1981.
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R. S. LEDDICK STATE OF WASHIrJGT0fl
)
) ss COUtlTY OF GRAYS HARBOR )
On this day personally appeared before me R. S. LEDDICK 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 pur-poses therein mentioned.
GIVEf1 under my hand and seal this 19 0 dayoff usost
, 1981.
m m
flota.'ylublic in and for the State of Washington Residing at FJ +
ATTACHMENT I Appendix A NOTICE OF VIOLATION A.
10CFR50, Appendix B, Criterion VI, states, in part:
" Measures shall be established to control the issuance of documents, such as instruc-tions, procedures, and drawings, including changes thereto, which pre-scribe all activities affecting quality. These measures shall assure that documents, including changes....are distributed to and used at the location where the prescribed activity is performed..."
Paragraph 17.2.6 of the Quality Assurance Program states, in part:
"... Approved changes are promptly included where applicable into in-structions, procedures, drawings, and other appropriate documents...
Obsolete or superseded documents are controlled to prevent inadver-tent use...."
Contrary to the above, as of April 16, 1981, the Ebasco Site Support Engin'eering (ESSE) Group had not established measures to assure that approved changes to documents are distributed and used. Seven draw-ings were identified in ESSE controlled file No. R-15 which did not include approved changes that applied to these drawings (WPPSS/Ebasco drawings 3240-G-2520-Sl; 2520-52; 2521; 2539; 2550; 1300-4; and 1325).
This is a Severity Level IV Violation (Supplement II), applicable to Units 3 and 5.
1.
Corrective Steps That Have Been Taken ESSE procedure, titled " ESSE Instruction for Document and Design Control" was written and issued. Also, the position of ESSE Vault Clerk has been created.
This person has responsibility for docu-ment control in ESSE including ensuring that design changes are added to the appropriate drawing.
The documents in drawing file No. R-15 including the above numbered drawings has been reviewed and updated as required.
2.
Corrective Steps Taken To Avoid Further Items Of Noncompliance Implementation of the ESSE procedure and training of personnel to that procedure should prevent future recurrence.
3.
Date Of Full Compliance Date of full compliance is anticipated by August 21, 1981.
B.
10CFR50, Appendix B, Criterion V, states:
" Activities affecting qual-ity 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 draw-ings.
Instructions, procedures, or drawings shall include appropriate
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quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Paragraph 17.1.5 of the Quality Assu ance Program states, in part:
... Contractors and vendors, including coasco and CE, are required to have written instructions, procedures, policies, and/or drawings which govern their quality related activities...."
e Specification No. 3240-412, (Formed Concrete Construction), para-graph 5.02, specifying quality related requirements for placing and field bending reinforcing steel, states, in part:
...Rebar shall be cold bent using proper bar bending equ',pment and the dia-meter of the bend measured on the inside of the bar shall not be less than the following...-
Bar Size Minimum Diameters Hos. 3 thru 8 6 bar diameters Nos. 9,10,11 8 bar diameters..."
Contrary to these governing instructions, on April 22, 1981, the reinforcing bar bending equipment, utilized by Morrison-Knudsen for field bending of safety related reinforcing steel, had bend-ing pin sizes which resulted in a bend inside diameter smaller than those required by the specification, for bar sizes 4, 5, 6, 8, 10 and 11:
by about 1.3 bar diameters for No. 4 bar; 2.24 bar diameters for No. 5 bar; 1.9 bar diameter for No. 6 bar; 1.25 bar diameters for No. 8 bar; 3 bar diameters for No. 10 bar; and 3 bar diameters for No. 11 bar.
This is a Severity Level V Violation (Supplement II), applicable to Units 3 and 5.
1.
Corrective Steps Which Have Been Taken NCRs were written to identify the nonconformance.
Tests were con-ducted wherein rebar was bent to the nonconforming diameters, em-bedded in concrete and subjected to tension testing. All results showed substantially greater than minimum required load perfor-mance.
Based on the above, Engineering concluded that no rework was re-quired for the installed rebar.
2.
Corrective Steps Taken To Avoid Further Items Of Noncompliance a.
M-K procedures were revised to require periodic surveillance by M-K QC to ensure satisfactory rebar fabrication.
b.
Comprehensive training of craft and QC associated with field fabricated at rebar has been performed.
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r c.
All bending pins have been properly marked to reflect appro-priate pin size.
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d.
A full set of templates has been placed at the bending machine.
3.
Date Of Full Compliance Full compliance was achieved on August 14, 1981.
C.
Morrison-Knudsen Administrative Instruction Procedure Number 15, " Stud Welding Inspection Procedure," includes quality test instructions which state in paragraph 6.3 that, "Each operator shall bend the first two studs on each day's production to 300 and the first two studs on each member to 300."
Contrary to the above, on April 15, 1981, on the south side of Unit 3 elevation 417', the inspector observed that a stud welding operator welding on a member (Number D1338) had welded twenty-four studs with-out bending the first two studs.
This repeat violation is a Severity Level V Violation (Supplement II),
applicable to Unit 3.
1.
Corrective Steps Which Have Been Taken An NCR was initiated to document the nonconformance. The appli-cable M-K procedure was revised to require, prior to continuing welding, the welding operator to bend and mark the first two studs on each beam. Training was completed on this revised procedure on July 20, 1981.
2.
Corrective Steps Taken To Avoid Further Items Of Noncompliance Implementation of the revised procedure and training of appli-cable personnel should prevent future recurrence.
3.
Date Of Full Compliance Full compliance was achieved on July 20, 1981.
D.
Ebasco drawing No. 3240-G-3357 which governs structural steel beam l
fabrication shows that stiffener plates are coped or clipped at the i
beam web and flange intersections and that fillet welds terminate at the coped edge of the stiffener plate.
Contrary to the above, on April 20, 1981, most of the stiffener plate welds on structural beams Nos. D1190, D35A, D63A, D64B, F18B, F69F, FllB, A25B, 318A, 308B, at a site storage area, did not terminate at the coped edge of the stiffener plates, but continued through the coped areas.
These beams had been previously inspected at the fabri-cation shops and accepted.
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I This is a Severity Level V Violation (Supplement II), applicable to Units 3 and 5.
1.
Corrective Steps Which Have Been Taken An NCR was initiated to document the nonconformance.
Design of the structural beams is based on the AISC Manual of Steel Con-struction. The welds are acceptable to the requirements of the AISC Manual, although the stiffener plate welds did not conform to the Ebasco drawing.
Based on this, the beams were accepted i
without further rework.
2.
Corrective Steps Taken To Avoid Further Items Of Noncompliance A DCN was issued May 19, 1981 to allow the fabricators the option of terminating or continuing the weld at the coped edge as per-mitted by AISC.
3.
Date Of Full Compliance Full compliance was achieved May 19, 1981.
E.
Administrative Site Procedure ASP-CM-4-17, Rev. 0 (entitled " Care and Issue of Measurine and Testing Equipment"), in effect from March 20, 1980 to March 3, 1981, and Project Site Procedure PSP-MM-ll-9, Rev. 0 (Interim) (entitled " Care and Issue of Measuring and Test Equipment"),
in effect since March 3,1981, provide detail instructions on the care, handling and issuance of calibrated equipment used to perform quality checks.
Both of these procedures state, in part, "... At no time is measuring and test equipment to be issued when any damage is suspected..."
Contrary to the above, calibrated torque wrench (Serial No. 33741) was returned to the calibration storage area on December 22, 1980, with a written statement indicating it was damaged, requiring repair. On March 6,1981, the wrench had not been repaired, but was issu d for use and was used to check the torque of bolts on a reactor ccalant pump motor suppcrt. As of April 16, 1981, the wrench torque gauge still had a broken glass and bent indicating needle.
This is a Severity Level VI Violation (Supplement II), applicable to Unit 3.
1.
Corrective Steps Which Have Been Taken The issuance of calibrated tools was suspended on April 20, 1981.
The history of the questionable torque wrench revealed the only prio use of this wrench was to check the tcrque on equipment stor-age tie downs of the reactor coolant pump motor support.
Upon submitting this wrench to the Owner's calibration facility, it was determined that the wrench was not out of calibration for the loading range that the wrench had been used.
Therefore, the use of this torque wrench did not result in any improper torquing opera ti ons.
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2.
Corrective Steps Taken To Avoid Further Items Of Noncompliance A site procedure concerning the care and issue of measuring and test equipment was revised to clarify action required in the event of discovery of damaged measuring and test equipment, and to incorporate appropriate requirements for care of the equip-ment. All personnel issuing calibrated equipment were trained to the revisea procedure.
3.
Date Of Full Compliance Full compliance was achieved on April 28, 1981,