ML20040A909
| ML20040A909 | |
| Person / Time | |
|---|---|
| Site: | Columbia, Washington Public Power Supply System, Satsop, Skagit  |
| Issue date: | 10/08/1981 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Rosalie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| Shared Package | |
| ML17275A566 | List: |
| References | |
| FOIA-81-366 NUDOCS 8201220296 | |
| Download: ML20040A909 (37) | |
Text
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,a NUCLEAR REGULATORY COMMISSION j
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g * *v f October 8,1981 Docket Nos. 50-397, 50-460, 50-513 50-508 and 50-509 Mr. Eugene Rosolie, Director Coalition for Safe Power Suite 527 Governor Building 408 Southwest Second Avenue IN RESPONSE REFER Portland, OR 97204 TO F01A-81-366
Dear Mr. Rosolie:
This is in response to your letter dated September 9, 1961 in which you requested, pursuant to the Freedom of Information Act,15 categories of records regarding the Washington Public Power Supply System (WPPSS).
Our response to each category of your request is discussed below.
1.
The requested previous letters, as listed under category 1 of Appendix A, are enclosed.
2.
The requested information is contained in inspection reports which are routinely placed in the two NRC Local Public Document Rooms (LPDR) for the WPPSS facilities.
As described in my June 10, 1981 letter to you, the LPDR located at Richland Public Library contains records pertaining to WPPSS Units 1, 2, and 4 under Docket Nos.
50-397, 50-460, and 50-513, respectively; and the LPDR located at the W. H. Abel Memorial Library in Montesino contains records pertaining to WPPSS Units 3 and 5 under Docket Nos. 50-508 and 50-509. For your assistance in searching for pertinent inspection reports at the appropriate LPOR, we are enclosing a computer printout, identified as Appendix B.
This printout includes a brief synopsis on each violation found by the inspector.
3.
NRC has no records subject to this category of your request.
(NRC has not prepared a financial analysis or other records on the financial status of WPPSS. for at least two or three years.)
4.
The surveillance of construction activities performed by NRC is described in inspection reports.
(See Appendix 8 discussed under category 2 above.)
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OCT13 igggj eggiagg296ettoos i,3 v.s. g g ROSALIE81-366 PDR ff
R2: F0!A-81-366 APPENDIX A Category 1 1.
6/17/80 Letter to Strand, WPPSS, from Stello, with stated enc (osures.
2.
6/17/80 Letter to Strand from Stello, "10 CFR 50.54(f) Request Regarding Quality Assurance", w/o stated enclosure which is provided under item No.1 above.
Category 6 1.
4/21/81 Letter to NRC from Matlock, WPPSS, "WPPSS Nuclear Project No. 2, Docket No. 50-397, CPPR-93, Potentially Reportable 10 CFR 50.55(e) Condition - WNP-2 No.144-215 Possible Installation of Defective 2" Sch. 80 Pipe", with attached interim report.
Category 7 1.
8/21/80 Memo to Knight from Jackson, "Possible Young Faults -
WNP/2 Puget Power New Site (Hanford)".
2.
9/2/80 Memo to Pressesky from Vollmer, "Recent Findings of Possible Capable Fault on Gable Mountain, Hanfiord Nuclear Reservation, Washington", with enclosed report:
9/2/80 - Memo to Vollmer from Justus, "Sumary of Recent Finding of Possible Capable Fault on Gable Mountain, Hanford Nuclear Reservation, Washington".
3.
9/2/80 Letter to NRC from Renberger, WPPSS, with attachment.
4.
10/30/80 Memo to Knight from Jackson, "WNP-2 Gable Mountain Fault Assessment".
5.
11/26/80 Memo to listed addressees from Justus, " Report of NRC Staff Visit to Gable Mountain Trench Exposures Hanford, Washington and to Other Geological Features October 16 and 17,1980 Concerning WPPSS-2 Operating License Review", with enclosed report:
11/21/80 - Memo to Jackson from Justus. " Report of NRC Staff Visit to Gable Mountain Trench Exposures Hanford, Washington and to Other Geological Features October 16 and 17,1980 Concerning WPPSS-2 Operating License Review",
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5.
With regard to "a", improvement or lack of improvement is determined through an analysis of information contained in the inspection reports.
With regard to "b", the " escalated enforcement action" involves enforcement meetings and/or issuance of civil penalties.
None of these actions have been taken since the issuance of a civil penalty in June 1980.
6.
A copy of en interim report is identified on Appendix A.
The report states that a final report will be prot ided by October 31, 1981.
7.
The requested records, as listed on Appendix A, are enclosed.
With regard to items 8 through 15 which refer to a 1972 Safety Evaluation Report (SER), the licensee subsequently addressed these issues in a Final Safety Analysis Report (FSAR) which is maintained in the appropriate LPOR.
The NRC staff is currently reviewing the FSAR and will issue a SER in March 1982.
are identified below.For your assistance, specific secticos of the FSAR 8.
Section 3.9.3, pp. 3.9-40 to 3.9-72.
9.
Section 3.9.3, pp. 3.9-40 to 3.9-72.
10.
Sections 5.4.5 and 6.7, pp. 5.4-10 to 5.4-17; 6.7-1 to 6.7-21.
12;13.
Section 3.9.2.4, page 3.9-38.
14.
Section 3.2. 2., page 3.2-3.
15.
Section 3.9.3., pp. 3.9-40 to 3. 9-72.
11.
The enclosed computer printout (Appendix B) lists information on violations on all WPPSS facilities.
The printout includes data necessary to track the inspection history from September 1980 to the present.
We appreciate your patience in awaiting our response.
The short delay was mainly due to preparation of Appendix 8 Sincyre
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/ J.
. Fel on. Director Div sion of Rules and Records Office of Administration
Enclosures:
As stated l
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8008 06-01-80 07-25-80 NONCOMPLIANCEI OTHER
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CONTRAPY TO THE REQUIPEMENTS OF 10 CFR 50, APPENDIX 8, CRITERION I, AS IMPLEMENTED BY THE PSAR, APPENDIX D, A REPRESENTATIVE, IN Al'TilDRITY, OF A SITE CONTRACTOR ESTABLISHED THEiAUTHORITY OFIA CONSTRUCTION GENERAL *SUPERINIENDENT TO ORDER TERMINATION OF.GA/GC
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-INVESTIGA EES 3
4 2927058 J3 CONTRARY TO THE REQUIPEHENTS OF 10 CFR 50, APPENDIX 8, CRITERION V, AS IMPLEMENTED BY THE PSAR, APPENDIX De AND CONTRACTOR QA PROCEDURE NO. 5, A CONTRACTOR EMPLOYEEiDID N3T DOCUMENT A NONCONFOR11NG SURVEILLANCE FINDING THAT IMPROPER MT PROSE CURRENTS
- 0 NERE USED IN MT EXAMINATIONS.
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8006 06-01-80 07-25-80 NONCOMPLIANCD OTHER
-INVESTIGA EES 2
A 2927058 Q
CONTRARY TO THE REQUIPEMENTS OF 10 CFR 50, APPENDIX 8, CRITERION V, AS IMPLEMENTED BY THE PSAR, APPENDIX D, AND CONTRACTOR QU LITY CONTROL PROCEDURD NO. 24, PIPE STOPS WITN CLEARANCES IN EXCESS OF REQUIREMENTS WERE: INSPECTED AND ACCEPTED 8Y QC A
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8006 06-01-80 07-25-80 NONCOMPLI ANCE!
OTHER
-INVESTIGA EE8 2
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CONTRARY TO THE REGLl!REMENTS OF 10 CFR 50, APPENDIX 8, CRITERION V, AS IMPLEMENTED BY THE PSAR, APPENDIX D, AND C9NIRACTOR WORK PROCEDURE NO, 81, Tdu WELos ATTACHING A PIPE SUPPORT TO THE SACRIFICIAL SHIELD WALL HAD NOT BEEN MAGNETIC PARTICLE EXAMINED.
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05000397 8003 06-01-80 07-25-80 NONCOMPLIANCEI OTHER
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4 2927058 CONTRARY TO THE REQUIREMENTS OF 10 CFR 50, APPENDIX e, CRITERION V, AS IMPLEMENTED BY THE PSAR, APPENDIX D, AND CONTRACTCR PROJECT DIRECTIVE NO. 75, CALCULATIONS wERE' NOT PROVIDED TO SUPPORT THE' DELETION OFi OR REDESIGN 3F WELDS ON THREE PIPING SYSTEM j
f' St'PPORTS.
(9 8008 06-08-80 07-25-80 NONCOMPLIANCEt OTHER
-INVESTIGA EED 3
A 2927058 CONTRARY TO THE REQUIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION Y, AS IMPLEMENTED BY THE PSAR, APPENDIX D, AND CONTRACTOR DOC MENT PACKAGE ~FOR A LOW PRESSURE CORE: SPRAY PU4P WAS REVIEMED AND i
PRDCEDURE SECTION 87 0F THE FIELD 04 NANUAL', AN INCOMPLETE U
ID ACCEPTED RT THE CONTRACTOR'S QA MANAGENENT.
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8008 06-01-80 07-25-80 NuMCOMPLIANCEt OfHER
-INVESTIGA EEB 2
A 2927058 l
CONTRAPY 70 THE REQUIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION V, AS IMPLEMENTED BY THE PSAR, APPENDIX D, AND CONTRACT SPECIFICATION NO. 2808-215, 18 SOCKET dELDS WERE: ACCOMPLISHED USING IMPROPER FILLER HETAL WITH THE. INCORRECT MELDING PROCEDURE.
C 8008 06-01-80 07-25-80 NONCOMPLIANCEI OTHER
-INVESTIGA-EEC 3
A 2427058
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CONTRARY TO THE REQUIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION V, AS IMPLEMENTED BY THE PSAR, APPENDIX 0, AND P!PlNG ISOMETRIC-l OF. LIQUID PENETR NT EX AMIN ATIONS MERE' PERFORMED TO ASME' SECTION VIII INSTEnD OF ASMEeSECTION DRAMING SPECIFIEP CODES, EVALUATION A
III.
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I 8006 06-08-80 07'-25-80 NONCOMPLIANCE OTHER
-INVESTIGA EFB 2
4 2927058 li 0
CONTRARY TO THE REuUIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION V',.AS IMPLEMENTED BY THE PSAR, APPENDIX D, THREE CONTRACIOR I
PROCEPURES SPECIFYING CONTROLS FOR TRACEABILITY OF* CERTIFIED MATERIALS MERE M301FIED BY THEeCONTRACTORs3 gg pgggg[p, gy 4
INTEROFFICE MEMO, WITHOUT PRIOR REVIEW AND APPROVAL' 0F THE' ARCHITECT ENGINEER / CONSTRUCTION MANAGER.
41 8008 06-01-80 07-25-80 NONCOMPLIANCEa OTHER
-INVESTIGA ETA 2
A 2927058
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CONTRARY Tu THE REQUIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION XVII, AS IMPLEMENTED BY'THE PSAR, APPENDIX De AND CONTRACTOR QA MANUAL, SECTIOff 10, AND WORK PROCEDUREINO. 12, RECORDS OF:TEMr0RARY WELD ATTACHMENTS HAD NOT BEEN HAINTAINED AS REQUIRED BY ASME i-CODEe SECTION III,
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8003 06-01-80 07-25-80 NONCOMPLIANCE-OTHER
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CONTRARY TO THE REGIIIPEMENTS OF 10 CFR 50, APPENDIX e, CRITERION XVII, AS IMPLEMENTED BY THE PSAR, APPENDIX D, AND SPECIFICATION NO 2908-215, THE CONTRACTOR FAILED TO PROVIDE A PROCEDURE' AND/OR C ECKLIST FOR DOCUHFNT REVIEN OF WORK PACKAGES AND HAD H
CEETIFIED AS COMPLETE TWO DOCUMENT PACXAGE S FOR SIRU TURAL'ST EL INSTALLATION.
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C 8006 06-08-80 07-25-80 NONCOMPLIANCEr OTHER
-INVESTTGA ETB 2
A 2927058 i ('
CONTRARY TO THE REQHIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION XVII, AS IrPLEMENTED BY THE PSAR, APPENDIX D, AND CONTRACT l
SPECIFICATION 2808*215 AND CONTRACTOR'S QA MANUAL, SECTION II, DOCUMENTA1 ION OF A VENDOR SURVEY WAS NOT MAINTAINED, AND' MATERIAL' HAD BEEN PURCHASED FPOM THAT VENDOR.
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Sul4 08-25-80 08-28-80 CLEAR INSPECTION ROUTINE!(
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A 292705C' 8086 09-01-80 09-30-80 NONCOMPLIANCEI INSPECTION ROUTINE CONTRARY TO THE REudIREMENTS OF 10 CFR 50,55(Eh THE LICENSEE' DID NOT N'3TIFY THE NRC INSPECTION AND ENFURCEMENT REGION AL> 0FFICE-C TilAT SAFETY-RELATED ELECTRICAL SWIT HGEAR HAD SEEN INSTALLED SUCN TNAT IT NAS UNKNOWN WHETHER THEiEQUIPMENT WOULD DPERATE 3
C PROPERLY DURING A DESIGN BASIS SEISMIC EVENT. E3 IENSIVE' EV ALUATION AND IN-SITU TESTING WERE REQUIRED TO DETERMINE THE-ACCEPTABILITY OF THE. INSTALLATION. THE'LTCENSEE'dAS NOTIF2ED BY THElARCHITECT-ENGINEER DN JULY 5, 1979.0F THIS CONSTRUCTION O
DEFICIENCY AND THAT AN EXTENSIVE EVALUATION PROGRAM NOULD BEiREQUIRED TO ESTABLISH THE ACCEPTABILITY OF4 THE INSTALLATION.
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4 392T058 CI to CFP 50, APPENDIX B,
CRITERION V, STATES IN PARTt ' ACTIVITIES AFFECT {NG QUALITY SHALL BE PRESCRIBED BY DOCUMENTED CD 14STRUCTIONS, PPOCEDURES, OR ORAMINGS OF A TYPE 8 APPROPRI ATE TO THE CgRCUMST ANCES AND SHALL BE ACCOMPLISHED IN ACCURDANCE MITH Tl4 SE INSTRHCTinNS, PPUCEDURES, UR ORAMINGS. INSTRUCTIONS, PROCEDURES, OR DRAWINGS SHALL INCLUDE APPROPRIATE' QUANTITATIVE OR ACTI ITIES HAVEtBE2N SATISFACIURILY ACCOMPLISHED." PARAGRAPH 1)
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'JNALITATIVE ACCEPTANCE CRITERIA FOR DENERMINING THAT IMPORTANT V
D.2.5.5 0F THE QA PROGRAM AS DELINEATED IN THE PSAR STATES IN PAPT: " ACTIVITIES AFFECTING QUALITY...SHALL BE ACCOMPLISHED IN ACCORDANCE MITH THESE INSTRUCT 10NSe PROCEDURESr OR DRAWINGS...*
C01 TRACT SPECIFICATION NO. 2808-215, SECTION ISA, PARAGRAPH 2.3 ANSI N15 2.2-19T2 AS A PLICABLE:FOR STORAGE'0F: INSTALLED EQUIPMENT. ANSI N45.2.2-19T2. STATES IN PARAGRAPH 6.4.1. THAT 1p
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- INSPECTIONS AND EXAMINATIONS SHALL BElPERFORMED AND DOCUMENTED ON A. PE IGE' HEATERS ENCLUSED IN ELECTRICAL ITEMS SHALL'DE R
ENERGIZEpe* AND IN PARAGRAPH 6.4.2 (B), THAT " ROTATING ELEC171 CAL EQUIPMENT SHALL BE GIVEN INSULATION NES! STANCE. TESTS ON SCHED LED UASIS.a THESE! REQUIREMENTS ARE IMPLEMENT D BY WBG WORK PROCEDURE NO. 106,
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MLINTENA"CE, REWORK AND REPAIR PROGRAM,"
ATTACHMENT 5.7 PARAGRAPH 4.3,3 STATES, IN parit
".....NUNCONFORMIING CONDITIONS SHALL'DE DOC'IMENTED ON THEiINSPECTION REPORT FORM-(IR) OR ON THE NONCONFORMANCE REPORT FORM (NCR)......"
CONTRARY TO THE INSPEC IONS dERE NOT PERF09MED ON STANDBY SERVICE: NATER PUMP 14 DORING THE'PERIUD FROM 1p
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REQUIREMENTS, R0tfTINE MAINTENANCE T
DECEMBER l i, 1979, TO AUGUST 21, 1930.
INSPECTION PERSONNELtDID NOT IDENTIFY THAT THE STAND 8Y $ERVICE WATER PUNP.14 NOTUR WINDING HCATER WAS NOT ENERGIZED DURING THElPERIOD FROM NOVEM8ER 10, 1980, THROUGH FEBRUARY 19, 1981 INSPECTION PERSONNELiDID MOT GENERA C AH INSPECTION REPORT OR NONCONFORMANCEsREPORT TO DOCUMENT AND RESOLVE.THE INA8ILITY TO MEGGER THE STAND 8Y SERVICE-19
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A 2370558 CD 10 CFR 50, APPEND!t R,
CRITERION V, STATES IN PART: " ACTIVITIES AFFECTING QUALITY SHALL' 8E; PRESCRIBED BY DOCUMENTED INSTRUCTIONS, PPOCEDURES, OR DRA"INGS Or A TYPE 6 APPROPRI ATE. TO THE CIRCUMST ANCES AND SH ALL 8E ACCOMPLISHED IN ACCORDf NCE' WITH
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THESE INSTDUCTIONS, PROCEDURES, OR 9RAWINGS.
INS 1 RUCTIONS, PROCEDURES, OR DRAWINGS SHALL INCLUDE APPRO'RIATE QUAFial4TIVE OR CD OHALITATIVE ACCEPTANCE CRITERIA FOR DEiTERMINING THAT IMPORTANT ACTIVITIES HAVEtBEEN SATISFACTORILY ACCOMPLISHED."
FARAGRAPH D.2.5.5 nr THE QA PROGRA9 AS DELINEATED IN THE PSAR STATES IN PART: " ACTIVITIES AFFECTING QUALITY...SHALL 8E ACCOMPLISHE0 IN (4
ACCORDANCE WITH THESE INSTRUCTIONS, PROCEDURE 8, OR DRANINGS..a BURNS.AND RDE (BAR) PROJECT INSTNUCTION NO. WNP-2-018, " DRAWING
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CONip0L' LPG (DCL) AND SPECIFIC ATION CONTROL' LOG (SCLil STATES, IN PARTI
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THE DCL DISPLAVS THE LATEST REVISION LEVEL' 0F EaCH 00HNS AND ROE DRAWING AND IDENTIFIES ALLtNOT YET INCORPORATED ENGINEERING CHANGEiDOCUMENTS (ECDS (SECTION A.11 DD (D
WNP-2-Ol8 IDENTIFIES PROJECT ENGINEERING DIRECTIVES (PEDSI AS ONE Or THE TYPES OF ECDS USED BY 88R))...(C.I.B.) A DRAWINGiMUST BE-(3 REVISED WHEN IT EITHER (A) HAS CHARGED AGAINST IT FIVE.(5) OR MORE ECDS WHICH HAVE' ASSIGNED BUSINESS DOCUMENTS (OR M SERIES PEDS WHICH ARE INSTALLED) OR, (B) AT LEAST ONE: (1) ECD WHICH IS OUTSTANDING GREATER THAN THREEt MONIHS (EXCLUDING W SERIES PEDS)..."
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CONTRARY To THE PEUMIPEMENTS, AS OF FEBRUARY 13, 1981, SURNS AND ROEtDRAWINGS M-601, M-611, M-630, M-805, AND E-539-52 WERE NUT C)
PEVISED WHEN THE DRAWING CONTROL LUG IDENTIFIED FIVE-(5) OR MORE PEDS WITH ASSIGNED BUSINESS DOCUWENTS, AND/OR AT LE AST DNE- (1)
PED OUTSTANDING GREATER THAN THREE-(3) MONTHS, AGAINST EACH Or THE REFERENCED DRANINGS.
9104 03-02-81 03-05-81 CLEAR INSPECTION ROUTTNEt(
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10 CFR 50, APPENDIX 8, CRITERION XVII, AS IWPLEMENTED BY SECTION 0 3-4-17, REGUIRES THAT " INSPECTION AND TEST RECORDS WILL, AS A MIN!"UM, IGENTITY THEINSPECTOR OR DATA RECORDEDI THE TYPE! 0F: 0BSERV ATION THE RESULTS THE'ACCEPTABILITYp AND THE' ACTION TAMEN I (.'
IN CONNECTION WITH ANY DEFICIENCIES NOTED."
THElW80 PROCEDURE QAP 211 REVISION O "NDE'FOR MAG. PARTICLE EXAMINATION" PART 4-5-1 di SHALL BEi RECORDED ON THE A PROPRI ATE BGVEE' AND CR AIL FORM,..THE INSFECTION REPURT FORM P
REQUIRES "THE RESULTS OF EACH INSPECTION HF-259 INCLUDING A ROLLOUT DRAWING IF REQUIRED, SHALL BE USED.*
CONTRARY TO THD REQUIREMENT, ON FEGRUARY 13, 1981, N!r MAGNET!C RSONNEL F AILED TO R CORD THE' INSPECTION DESUL S (TYPE OFe INDIC ATION) WHICH REVEALED EXIST ANCD OF6 A PARTI AL-15 E
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PARTICLE INSPECTION PE PENETRATION HELD WHEPE A FULL PENETRATION dELD WAS DESIGNATED UN LECKENBY DESIGN DRAWING 466 FOR THE SACRIFICIAL SHIELD WALL.
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H008 r) q 05000397 Sito 05-01-81 05-31-81 CLEAR INSPECTION ROUTINEl(
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A 249063C-O 05000460 8001 01-01-80 01-31-80 NONCOMPLIANCE', THAT ' ACTIVITIES AFFECTING QUALITY SHALL BE PRESCRIBED BY DOCUMENTED STATES, IN PART l
10 CFR 50, APPENDIX u, CRITERION V, l
INSTRUCTION 3e PROCEDURES GE DRAWINGS, OF A TYPE' APPROPRI ATE TO THE C3 RCUMST ANCES...."
WPPSS CONTRACT SPECIFICATION 211 AND 257 i
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FOR THE INSTALLATION OF PIPING SPECIFIES TtfAT ATTACHMENTS TO STRUCTURAL STEEL SHALL~BE DONE IN ACCORDANCE WITH THEIAWS l
STRUCTURAL WELDING CODE D.l.1-1974 PART 8.14 0F THIS CODE: REQUIRFS THAT TEMPORARY WELDS SHALL BE SUBJECT to THE SAME WELDING PROCEDURE RERUIPEMENTS AS FINAL WELDS.
ALS0e PART 3.2 0F THIS CODE REQUIRES CLEANING OF FOREIGN HATERIAL FRFM SURFACES TO BE 1980, NO DOC MENTED INSTRUCTIONS, PROCEDURES OR D 44 WINGS WE RE-U
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CONTR ARY TO Tl'ESE REQUIREMENTS, AS OF JANUARY 28, PROVIDED TU CpHTROL THE INSTALLATION AND REH0 VAL!0FITZMPORARY ATTACHMENT WELDS TO STRUCTURAL STEEL UF THE UkIT 1 GENERAL-A SAFE.TY-RELA ED STRUCTURE'.
TEMPORARY ATTACHMENTS WERE WELDED TO THIS STRUCTURAL STEEt. DITHOUT CLEANING T
SERVICES BUILDING, S
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PAINT FROM THE AREAS TO BEiWELDED.
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4 249063C 10 CFR So, APPENPIX 0, CRITERION V, STATES, IN PART, THAT " ACTIVITIES AFFECTING QUALITY SHALL BE PRESCRIBED BY DOCUMENTED TYi'E' APPROPRI ATE TO THE CI CUMST ANCES AND SHALL BE' ACCOMPLISHED IN ACCORDANCE WITH R
INSTRUCTIntv3, PROCEDURES OP DR AWINGS OF' A
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THESE INSTRUCTIONS, PROCEnURES, OR DRAAINGS...."
CONTRARY TO THIS, ON JANUARY 3, 1980, PIPE SUPPORT NOS. MUS-103-8G-2 AND DHR-036-SG-3 EACH HAD ONE' FILLET WELD THAT WAS 1/16 INCH UNDERSIZF AND. PIPE SUPPORT DHR-035-SG-4 HAD UNI FILLET WELD THAT WAS t/A INCH UNDERSIZE FHO*f THAT SH0d4 DN THE SUPPORT FARRICATION DRAWgNGS. THESE' WELDS HAD RECEIVED QUALITY CONTROL INSPECTION AT 9
(.
THE VENn0P SHOP AND dERE CONSIDERED ACCEPTABLE.
i l
O 8002 02-11-80 02-15-80 CLEAR INSPECTION ROUTINE! (
=
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EXCLUDES 2.790 INFORMATION
'C 90CMET/ REPORT INSP/0ATES F]NDINGS Ex CODE SEV TYPE MOD 8 O
Q C
05000460 8093 02-61-80 02-29-80 CLEAR INSPECTION ROUTINEl(
=
8001 03-01-90 03-31-80 DEVIATION INSPECTION ROUTINEf(
PSA C.
255073C-CONTRARY TO THE LICENSEE'S COMMITMENT IN PARAGRAPH 5'.'2,2.1 AND TABLEq5.2-5 0F THE<PSAR THAT WELD MATERIAL SPECIFICATION SAF-5,5 O
WOULD GOVERN THE SPECIAL E-7018 "ELDING ELECTRODES USED FOR REACTOR COOLANT PRESSURE BOUNDARY MELDS, MELDING ELECTRODES Ol uuALIFIED UNr>ER SPECIFICATION SFA-5.1 RATHER THEN SFA-5.5'WERE USED'FOR WFLDING THE' PIPE-TO-ST E A4 GENERATOR REACTOR CO PRES WPE ROUNDARY MELOS.
Sous 03-31-80 04-03-80 CLEAR IN3PECTION ROUTINE: (
C ION POUTINEr(
EEB 2
A 2500908 f
8006 01-29-80 05-02-80 NONCOMPLIANC9 INSPEC{5' 0F THE QUALITY ASSURANCE PROGRAM DOCUMENTED IN THElP 10 CFR 50, APPENDIX R,
CRITERION V, A3 IMPLEMENTED BY SECTION 17.l.
THE dPPSS GA PROGRA1 MANUAL PROCEDURE QAP-2, PARAGRAPH 3.le STATES IN PART THAT, " ACTIVITIES AFFECTING QUALITT...SHALL BE f
ACCOMPLISHED IN ACCORnANCE,WITH... INSTRUCTIONS, PROCEDURES, OR DRAWINGS,"
THElHANGER INSPECTION CHECKLIST OF THE'J. A. JUNES l
CONSTRUCTIUN COMPAht, THEiSITE CONTRACTOR RESPONSIBLE FOR INSTALLATION AND INSPECTION OF. HANGERS FOR SAFETT-RELATED PIPING, REQLtIPES VERIFICATION THAT U-BOLT CONNEC 10NS ARE TIGHT, ADDITIONALLY, J. A. JONES INSTRUCTION NO. JAJ-wl-Oln,3, REVISION lA, T
f PARAGPAPH 8.7, STATES THAT " AFTER COMPLEY a N OF! H ANGER INSTALLATION, INCLUDING THE DCCUMENTATION REQUIRED UN HANGER INSTALLATION SRETCH, THE HANGER d!LL DE; TAGGED WifH AN URANGEiADHESIVE' TAG.TO PREVENT ANY FURTHER MORK WITHOUT NOTIFYING PROJECT ENGINEERING AND QA.
IF ADDITIGNAL WORK IS APPROVED, DOCUMENT ATION FOR THE WORx MUST BE' PROVIDED BY J.
A. JUNES ENGINEERING." CONIRARY TO C^
THESE REQUIREMENTSe UN MAY le 1980 AT UNIT t, PIPEiHANGERS NUS. DHR-15 SG-19 AND DHR-15-SG-20 SUPPORTING SAFETY-RELATED PIPING-THIS NONC Nr0RMING CONDITION WAS NOT IDENTIFIED, AND THE: HANGER INSPECTION CHECMLISTS DOCUMENTED O
HAD LOOSE U-HDLT CONNECTIONS.
THAT THESE U-DOLT CONNECTIONS HAD BEEN INSPECTED AND FOUND ACCEPTABLE. ORANCE' ADHESIVE TAGS MERE APPLIED TU lHE HANGERS, AND NO APPROVED.
C DOCtNENT AT ION DEMONSTRATED THAT ADDITIONAL WORK ON THE HANGERS SUBSEOUENT TO THE' INSPECTION AND T AGGING HAD BEEN INSPECT ON ROU11NE' (
ENA 2
A 292706B I
C 8006 04-29-80 05-02-80 NONCOMPLIANCEI 10 CFR 50, APPENDIX R, CRITERION XIII, AS IMPLEMENTED BY SECTION 17.1.13 0F'THE-QUALITT ASSURANCE' PROGRAM DOCUMENTED IN THE PSAR AND THE >PPSS QA PROGRAM MANUAL PROCEDURE'3AP-16, PARAGRAPH 4.1, STATES IN PART THAT, " M ASURES SHALL BE ESTABLISHED TO' CONTROL O
THE HANDLING, STORAGE, SHIFPING, CLEANING AND PRESERVATION OF' M ATERI AL AND EQUIPMENT...TU MEVENT DAM AGE OR DETERIURATION."
Q PARAGRAPH 6.l.2 0F PROCEDURE PDP-N-405W OF THE J.
A. JONES CONSTRUCTION COMPANY, A SITE'CfMTRACTOR RESPUNSIELE'FOR CONSTRUCTION ACTIVITIES INVOLVING SAFETY-RELATED P! PING AND COMPONENTS, STATES THAT FOR PIPING AND COMPONENTS, "PROTECTIVEfCOVERING, END C APS j
l D
AND OTHER PROTECTIVE PEVICES MILL BEiUTILIZED AND HAINTAINED." FURTHER, PARAGRAPH 6.3 0F J A. JONES PROCEDURE JAJ-WI-005, O
REVISION 2E, STATES THAT, " SPACE HEATERS FOR EQUIPMENT SET IN PLACE SHALL BE ENERGIZED WITHIN TMO DAYS AFTER EQUIPMENI IS INSTALLED." CONirARf TO THESE.REQUgREME TS, ON APRIL 29, 1980s (g) AT THE J.
A. JONES LAYDOWN TARD FOR UN7T 1 PIPING, N
WATER, AND
(>
SAFETY-RELATED STAINLESS STEEL PIPE SPOOL'NO. D3R-il5-040-55 H40 OwElEND UNCAPPED AND CONTAINED 4 QUANTif7 OF l 4 SAFETY-RELAftn STAINLESS STEEL PIPE SPOOL'NO. BRS-Cl06-84-51 HAD BOTH ENDS UNCAPPED.
(2) THE BUWL OF> UNIT I REACTOR COULANT PIMP NO. PIA 2, A SAFETT-RELATED COMPONENT, W AS UNCDVERED AND TFE 80 L' CONTAINED DEBRIS TNCLUDING FOOD, NEWSPAPER AND PAPER d
!,O PRODUCTS, (3) AT THE 455 FOOT ELEV ATION OF' THE' UNIT I GENERAL SERVICES BUILDING, SEVERAL UNCOVERED SAFETY-RELATED STAINLESS i
1 STEEL PIPE SPOOLS AND VmLVES FOR UNIT IdERE TEMPORARILY STOREE WITHOUT PROTECTIVE CAPS INSTALLED AND NERE COVERE FROM CONCPETING MOR*.
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0 1.O HISTORY-JAN 80 TO PRESENT PAGE 8 09/25/31 WPPS$ INSPECT 4 EXCLUDES 2.790 INr0RMA110N C
SOCMET/ REPORT INSP/ DATES FINDINGS Ex CODE SEV TTPE' MODS 0
05000860 8007 04-01-80 04-30-80 NONCOMPLIANCEI INSPECTION'ROUTINEi(
EEB 3
A 251053C' O
CONTRARY TU 10 CFR 50, APPENDIE Be CRITERION V, AND DETAILS T30 AND T400 0F FABRICATION DRAWINGS FOR ELECTRICAL CABLE TRAY StfPPORTS 174-3101-3004 A4D 1T6-3413-2910, TWO F1LLET WELDS WERE I/l6-INCH UNDERSIZED FOR THE FULL 1 LENGTH UF THE WELDS.
8006 0T-14-80 07-18-80 CLEAR INSPECTION ROUTINEI(
0 O
O 0
8009 05-08-80 05-30-80 CLEAR INSPECTION ROUTINET(
=
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8010 06-02-80 06-09-80 NONCOMPLIANCE' INSPECTION ROUTINE-(
EEB 2
A 255063C to CFR 50, APPENDIX 0, CRITERION V,
AS IMPLEMENTED Ry SECTION 17.1.5 0F THE QUALITY ASSURANCE PROGRAM DOCUMENTED IN THElPSAR AND f
THE aPPSS G4 PROGRA4 MAHUAL, PROCEDUREiQAr-2, PARAGRAPH 3.1, STATES IN PART THAT, " ACTIVITIES AFFECTING QUALITY SHAT.L BEi O
PRESCRIDED DY DOCUMENTED INSTRUCTIONS, PROCEDURES OR DRAWINGS OF A TYPE APPROPRI ATE: TO THE' CIRCUMSTANCES AND SHALL. 8E ACC09PLISHLD IH f.CCORDANCE,WITH THESE INSTRUCTIONS, PROCEDURES OR DRAWINGS...."
ALLIED-CAPITUL JOINT VENTURE DRAWING NO.
O FCH-495, PLVISION 1, SPECIFIES 5/l6-INCH FILLET WELDS FOR STRUCTURAllSTEEL COLUMN NO. 2270A AND A I/2-INCH FILLET WELD FOR THE O
ATTACHMENT CLIP DN COLUMN NO. 2283. CONTRACT SPECIFICATION NO. 207 REQUIRES IHESE COLUMNS TO BE FABRICATED IN ACCORDANCE WITH REQt'IREMENTS OF THE AWS D1.1 STRUCTURAL' dELDING CODE.
THIS CDDE PFRMITS FILLET WELD SIZE TO UNDERRUN THE SPECIFFED NU11NAL'.
THE' LENGTH OF' THE O.
(-
FILLET MELD SIZE BY t/16-INCH WITHOUT CORRECTION PR0 SIDED THAT THE UNDEPRUN DOES NOT EXCEED TEN PERCENI 0F MELD.
00'11RARY TO THE REQUIREMENTS, ON JUNE' 2, 1980, THElSIZES OF. FILLET WELDS ON COLUMN NO. 2270A NERE LESS THAN 1/4-INCH UVER THE FULL LENGTH OF THE WELDS, AND THE' ATT ACHMENT CLIP FILLET WELD ON COLUMN NO. 2283 M AS 3/8-INCH OR LESS OVER THE FULLt LENGTH O
jD OF THE WELD.
O 8011 08-26-80 09-12-80 NONCOMPLIANCE!
INSPEC{ ION ROUTINEt(
EEB 2
4 2490538 9
10 CFR Sg, APPENPIX 0, CRITERION V, AS IMPLEMENTED BY SECTION 17.l.5 0F THE QUALITY ASSURANCE PROGRAN DOCUMENTED IN THE' PS AR AND THE dPPSS un PPOCRAN MANUAL PROCEDURE QAP-2, PAU GRAPH 3.le ST ATES IN PART THAT "4CTIVITIES AFFECTING QUALITY SHALL' 8E' O
PRESCRIgEfi OT DOCUMENTED INSTRUCTIONS, PROCEDURES OR DRAWINGS, OF A TYPE APPROPRIATE TO THE CIRCUMSTANCES AND SHALL BE ACCO1PLISHED IN ACCORDANCE' WITH THLSE' INSTRUCTIONS, PROCEDURES OR DRAWINGS...."
DETAIL' DRAWING NO. DHRX=35 (WPPSS DRAWING NO.
97T9-F-412030, REVISION 3) FOR PTPE SPOOLt DHR-412030-2 0F5THEIDECAY HEAT REMOVAL SYSTEH SPECIFIED 5/16" FILLET WELDS FOR THE
(*
ATTACHMENT OF EIGHT PIPE STOP BLOCKS TO THEiSPOOL PIPING. CONTRARY TO THE REQUIREHENTS, ON AUGUST 27e' 1980, TWO Wt LDS AT T ACHING TWO PIPE STOP OLOCMS TO THE PIPE MERE t/4" FILLET WELDS.
THESE WELDS HAD BEEN INSPECTED AND ACCEPTED 8Y THE VENDOR (R. F.
SHAN)
ON APRIL 21, 1980.
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09/25/81 WPPSS IH4PECT. HISTORY-JAN 00 TO PRECENT PAGE 9 EXCL'L3 S 2.790 INFORM AT ION iO 90; MET / REPORT INSP/ DATES FINDINGS Ex CODE SEV TYPE M008 Q
l INSPECTION ROUTIND (
EER 2
4 2490538 O
05000eo0 8081 08-26-80 09-12-80 NONCOMPLI ANCD lO 10 CFR 50, APPENplX B, CRITERION V, AS IMPLEMENTED BY SECTION 17.1.5 0F THE GA PROGRAM DOCUMENTED IN THE PSAR AND THE WPPSS QA I
PROGRAM M A N'J AL PROCEDHRE Q AP-2, P AR AGR APH 3.1, STATES IN PART THAT " ACTIVITIES AFFECTING QUALITY SHALL 8E PRESCRIBED BY
, O DOC L'* E N T E D INSTRUCTIONS, PROCEDURES OR DRAWINGS, OFr A TYPE' APPROPRI ATE TO THE CIRCUMST ANCES AND SH ALL' BE ACCOMPLISHED IN Ql ACCORDANCE WITH THESE INSTRUCTIONS, PROCEDURE 8 DR DRAWINGS....'
PROCEDURE NO. FGCP-48, REVISION 0
(" CORRECTIVE MAINTENANCE MANAGEMENT *)
SPECIFIES IH PARAGRAPH 5.0 THAT "Altc.4AINTENANCE PERFO MED UNDER THE MAINTENANCE MANAGEMENT PROGRAM MILL SO R
O ACCOMPLISHED DY MAINTENANCE WORK REQUEST.'
THIS PROCEDURE IS APPLICABLE TO REPAIR OR MODIFICATION WORK REQUIRED ON PREPURCHASED Q
MATERIAL, CONTPARY TO THE REQUIREMENTS, DURING THD PERIOD AUGUST 26-27, 1980, FIVO ARC STRIMES WERE REMOVED FROM PIPE SPOOL NO.
DHR-182U30-2 WITHOUT HSING A MAINTENANCE NORK REnUEST TO AUTHORIZE THE NORK.
ADDITIONALLY, NO RECORDS WERE PROVIDED TO DOCUMENT O
THE METHODS USED TO REMOvD THE ARC STRIKES NDR EXAMINE THE REPAIRED AREAS.
THIS PIPE SPOCc IS PREPURCHASED MATERI AL' FOR THE.
O DECAY HEAT PEMOVAL SYSTEM.
8082 10-09-80 10-09-80 CLEAR INSPECTION. SPECI AL'
=
3 C
8913 10-20-80 10-23-80 NONCOMPLI ANCD INSPECTION ROUTIND (
EDA a
A 2350618-O 10 CFR 50, APPENDIX 8, CRITERION TV, AS IMPLEMENTED BY SECTION 17.1.4 0F.THE DA PROGRAM DOCUMENTED IN THE PSAR STATES, IN PARTE O
THAT "HE ASUPES SHALL' BE EST ABLISHED TO ASSUPEITMAf APPLICABLL. REGULATORY REQUIRIMENTS, DESIGN BASES, AND OTHER REQUIREMENTS WHICH ARE NECESSARY TO ASSURE ADEQUATEtQUALITY ARE; SUITABLY INCLUD D OR REFERENCED IN THE DOCUMENTS FOR PROCUREMENT OF MATERIAL, i O EQUIPMENT, AND SERVICES, dHETHER PURCHASED BT TME APPLICANT OR SY TS CONTRACTORS OR SU8 CONTRACTORS...."
CONTRARY TO THE' '
l RE Ql'I PE ME NT S, AS OF OCTOBER 23, 1980, THEi ME ASURES EST ABLISHED BY THD ST TE MECHANICAL CONTRACTOR AND IHEIR PAINTING j
SUBCONTPACTOR NERE NOT ADEQUATE TO ASSURD THAT PROCUREMENT D00UMENT! INCLUDED THOSE: REQUIREHENTS NECESSARY TO ASSURE ADEQUAIE O
QUALITY OF THE PAINT TO DEiUSED ON EQUIPMENT WITHI4 THEiCONTAINMENT. CONTRACT SPECIFICATION NO. 9T79-211 REQUIRES THE PAINI TO l
HAVE A DECONTAMINATION FACTOR OF TEN.
THE PAINT ORDERED, RECEIVED AND PLACED IN STORAGE FOR USE HAD A DECONTAMINATION FACTOR OF.
i 6.3.
g i
8014 03-06-80 07-17-80 CLEAR UTHER
-INVESTIGA G
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00CMET/ REPORT INSP/ DATES F1NDINGS Et CODE-SEV TYPE
- MUDS Q
i 05000460 8015 11-17-80 12-05-80 NONCOMPLIANCEI INSPEti!ON ROUTINEi(
EE8 5
A 2927068 O
19 CFP 50, APPENDIX R, CIRTERION V, AS IMPLEMENTED BY SECTION 17.l.'5 0F THE QUALITY ASSURANCE PROGRAM DUCUMENTED IN THE!PSAR AND THE dPPSS QA PROGRAN MANUAL PROCEDURE QAP-2, PARAGRAPH 3.le STATES, IN PART, THAT " ACTIVITIES AFFECTING QUALITY SHALL SE-O PRESCRInED DY DOCUPENTEP INSTRUCTIONS, PROCEDURES OR DRAWINGS, OF A TYPE' APPROPRIATE'TO THE CIRCUMSTANCES AND SHALL BEI O
ACC09PLISHED IN ACCORDANCE htTH THESE INSTPUCTIDNS, PROCEDURES OR DRAWINGS.."
DETAIL DRAWING NO. CK37847, DETAIL 3, ISSUED TO J.A.
JONES CONSTRUCTION COMPANY BY UNITED ENGINEERS AND CONSTRUCTORS.REGARDING THE INSTALLATION OF NUCLEAR SERVICE WATER HEAT O
EXCHANGERS, AN ACTIVITY AFFECTING QUAL,lTY, SPECIFIES THAT WASHERS AREi10 BE INSTALLED BETWEEN THE. ANCHOR BOLT NUTS AND THEi O
BASEPLATES OF THE HEAT EXCHANGERS. CONTRARY TO THEiREQUIREMENTS, ON NOVEMBER 17, 1980, NONE OF THE 32 ANCHOR BOLTS USED FOR ATTACHING THE HMCLEAR SERVICE WATER HEAT ErCHANGERS lA AND 2B TO THE1R FOUNDATIONS HAD WASHERS INSTALLED BETWEEN THE' NUT AND O
BASEPLATE. THE TOR 90 LNG OF THE ANCHOR BOLT NUTS HAD BEEN COMPLETED AND VERIFIED BY J.A. JONES INSPECTION PERSONNEL DN FEBRUARY O
e 14, 1980.
J.A. JONES CONSTRUCTION COMPANY PROCEDURE NO, POP =N*S0lW (USE 0F PROCESS CONTRULtSHEETS) SPECIFIES IN PARAGRAPH-5,3 THAT ' MANDATORY HOLD POINTS SHALL BElSIGNED OFFIBY Ot)ALITY VERIFICATION
- AND FURTHER SPECIFIES IN PARAPRAPH 6.5 THAT
- WORK SHALL-O NOT PROCEED PAST THE' HOLD POINT UNIIL QUALITY VERIFICATION SIGNOFF OE THE PROCESS CONTROL SHEET."
CONIRARY TO THE' REQUIREMENTS, O
AS OF'NOVEM0ER 18, 1980, WORK HAD PROCEEDED PAST THREE HOLD POINTS WITHOUT QUALITY VERTFICATION SIGNOFF UN J.A. JONES PROCESS CONTROL SHEET NO. JAJ-MI-0278 THIS PROCESS CONTROLISHEET WAS USED FOR CONTROL OF.THE INSTALLATION OF NUCLEAR SERVICE WATER O
HEAT EXCHANGER NO. 28, A QUALITY AFFECTING ACTIVITY.
D 8015 11-17 80 12-05-80 NONCOMPLIANCE' INSPECTION ROUTINEr(
.EEC 5
A 2927068 g
10 CFR 50, APPENDIX R, CRITERION V, AS IMPLEMENTED BY SECTION 17.1.'5 0F THE QUALITY ASSURANCE PROGRAM DOCUMENIED IN THEtPSAR AND Tite dPPSS QA PROGRA1 MANUAL PROCEDURE QAP-2 PARAGRAPH 3,1 STATES, IN PART, THAT = ACTIVITIES AFFECTING QUALITY SH ALL' BE
{
PRESCPinED BY DOCUMENTED INSTRUCTIONS PRDCEDURES AND DRAWINGS, OF A TYPE APPROPRIATE TO TPE CIRCUMSIANCES AND SHALL RE 3
ACCOMPLISHED IN ACCORDANCE WITH THESE INSTRUCTIONS, PROCEDURES, OR DRAWINGS.
INSTRUCTIONS, PROCEDUNE3 UR DRAWINGS SHALL INCLUDE' APPROPRIATE QUANTITATIVE OR QUALIYATIVElACCEPTANCE CRITERIA FOR DETERHINING THAT IMPORTANT ACTIVlill! HAVE BEEN SATISFACTORILY
? (
ACCOMPLISHED.'
TARLE 3.2-2 0F THE PSAR SPECIFIES THAT THE.CONTAINMF,NT SPRAY SYSTEM PIPING WILL N ET THE REQUTREMENTS OF THE
@~
ASME BOILER AND PRES $UFE VESSEL CODEIFOR SECTION III, CLASS 2 PIPING. SU6SUBARTICLES NC3660 AND NC4240 0F THE'ASHE BOILER AND PRESSURE VESSEL CODE FOR SECTION III, CLASS 2 PIPING SPECIFIES REQUIREMENTS FOR WELDED JOINIS, INCLUDlNG WELD DIMENSION AND
('
GEOMETRY, CONTPART TO THEIRCQUIREMENTS, AS OF NOVEMBER 18, 1980, 3/4-INCH DIAMETER THREAD 0LET FITTINGS HAD BEEN <TLDED TO THE O
10-INCH DIAMETER CONTAlH4ENT SPRAY PIPING AND THE J0!NING WELDS WEREIINSPECTED AND ACCEPTED BY THE'CONTRACTORI ALTHOUG4, THE.
WELD DIMENSIONS A D GEOMETRY WEHE'NOT INCLUDED IN THE INSTRUCTIONS, N
QUANTITATIVE ACCEPTANCE CRITERIA 0F THEL ASME' CODE FOR O_
PROCEDURES OP DRAdINGS USED TO CONTROLiTHE WORK.
INSTALLATION OF THESE FITTINGS WAS SPECIFIED BY UNITED ENGINEER AND C OR'S FIELD CHANGE NOTICE NO. 211-l 80-113, REVISION I AND ISOMETRIC DRAWING NO. 412443, REVISION 2.
NEITHER THE:
CONSTRU T
WE E CDCNIZANT OF THE CODES WELD SIZE + REQUIREMENTS, WELDEPS OR INSPECTORS PERFORMING THIS QUALITY AFFECTING ACitvITY R
G 8086 12-16-80 12-19-80 NONCOMPLIANCEI INSPECTION ROUTINEl(
EEB 4
A 2500908
(, -
10 CFR 50, APPENDIX R, CRITERION V, AS IMPLEMENTED BY SECTION 17.l.5 0F THE QUALITY ASSURANCE PROGRAM DOCUMENTED IN THEtPSAR AND THE WPPSS QA PROGRAM MANUAL PROCEDUREIQAP-2, PARAGRAPH 3.1 STATES, 1N PART, THAT " ACTIVITIES AFFECTING QUALITY SHALL SE' PRESCRIBED BY DOC NENTED IN3TRUC IONS, PROCEDURES AND DRAWINGS, OF A TYPE APPROPRIATE TO THE CIRCUMSIANCES AND SHALL bet H
T h
ACCOMPLISHED IN ACCORDANCE WITH THESE INSTRUCTIONS, PROCEDURES OR DRAWINGS.* DRAWING NO. 9T79-LL-417652 FOR SUPPORT NO.
O III, SU SECTION NF CLA S 3 SUPPORT, IN 1CCTION A-A DEPICTS THE SHOP WELDING CCW-54-SG-106, A WPPSS QUALITY CLASS la ASME:
B S
CONFIGURATION FOR THE UPPER BEAM TO WALL ATTACHNENT PLATE JOINT. CONTRARY TO THE REQUIREMENTS, AS OF DECEMBER 18, 1980, THE AS I'O INSTALLED SHOP WELD CONFIGURATION FOR THE UPPER BEAH TO WALL' ATTACH ENI PLATE JOINT DID NOT CONFORM TO THAT SPECIFIED BY THE g
N DRAWING IN THAT THE JOINT CONFIGURATION WAS RnTATED 180 DEGREES FRnN DRAWING ORIENTATION REQUIREMENT, THE SUPPORT WAS INSPECTED l'
AND ACCEPTED DY THE MATERIAL SUPPLIER ON APRIL 2rt, 1979 O
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O 09/25/01 WPPOS INSPECT, HISTORY-JAN 30 TO PRESENT PAGEi11 EXCLUDES 2.790 INFORMATION FI DINGS Et CODE.
SEV TYPE 8 MUD 8 O
N G
OOCkET/ REPORT INSP/ DATES
(
05000460 8086 12-16-80 (2-19-80 NONCOMPLIANCEI INSPECTION ROUTINE (
EES 4
4 2927028 0
to CFR 50, APPENDIX 8, CRITERION Ve AS IMPLEMENTED BY SECTION 17.1.'5 0F THE QUALITY ASSURANCE PROGRAM DUCUMENTED IN THE PSAR AND THE MPPSS UA PROGRAN MANUAL PROCEDURE QAP-2, PARAGRAPH 3.1, STATES, IN PART THAT " ACTIVITIES AFFECTING QUALITY SHALL bel
('
PRESCRIRED BY DOCUMENTED INSTRUCTIONS, PROCEDURES OR DRAWINGS, OF A TYPE APPROPRIATEiTO THE.CIRCUHSTANCES AND SHALL BE O
ACCOMPLISHED IN ACCORDANCE.WITH THESE1 INSTRUCTIONSe PROCEDURES OR DRAWINGS..."
SECTION 1A, P AR AGR APH 11.2, OF' WPPSS QU ALITY CLASS I NUCLEAR SAFETY-RELATFD CONTRACT SPECIFICATION NOS.
9779-23e 41, 62 AND ll3.STATESe IN PART, fHAT "ALLiCONTRACTOR88 C
DRAWINGS SUnMITTED SHALL BE POSTED dITH THEtWPPSS QUALITY CLASS AS DESIGNATED IN THE8E DOCUMENTS AND AS CALLED FOR ON THE' O
ENGINEEP'S DESIGN DRAWINGS."
CONTRARY TO THE REQUIREMENTS e AS OF DECEMBER 17, 1980, (1) FOUR CONTRACTOR DRAWINGS FOR SPECIFICATION 9779-23: (2) FIVE CONTRACTOR DRAWINGS FOR SPECIFICATION 9779-411 (3) THREE CONTRACTOR DHAWINGS FOR SPECIFECATION O
NO. 9779-627 AND (1) SIX CONTRACTOR DRAWINGS FOR SPECIFICATION NO. 9779-113 WERE: NOT POSTED WITH THE WPPSS QUALITY CLASS, AS O
DESIGNATED.
8tel 01-13-81 01-16-81 CLEAR INSPECTION =ROUTINEl(
C 8102 01-26-81 01-30-81 NONCOMPLIANCE OTHER
-INVESTIGA EEA 4
A 2927058 f
to CFR 50, APPENDIX Re CRITERTON V, AS IMPLEMENTED BY SECTION 8 7, l.'5; 0F THE QUALITY ASSURANCE PROGRAM DUCUMENTED IN THEiPSAR AND THE mPPSS QA PROGRA4 MANUAL PRDCEDURE QAP-2, PARAGRAPH 3.1, STATES, IN PART, THAT ' ACTIVITIES AFFECTING QUALITY SHALL' SE.
PRESCHIBED BY DOCUMENTED INSTP?CTIONS, PROCEDURES OR DRAWINGS, OF A TYPE: APPROPRIATE.TO THE' CIRCUMSTANCES AND SHALL'SE D AMINGS...'
CONTRARY TO THEiREQUIPFHENTS, PRIOR TO JUNEe 3
f ACCOMPLISHED IN ACCORDANCE WITH THESE.INSTPUCTIONS, PROCEDURES OR R
1990e UNIYtPSITY NUCLEAR SYSTEMS, INC. (UNSI) INITIATED THE'USE OF A FORM TITLED " QUALITY CONTROU PROBLEM REPORT
- TO IDENTIFY HONCONFORMANCES, DEFICIENCIES AND PRO 1LEMS WITH ACTIVITIES AFFECTINoi THE QUALITY OF4 CONSTRUCTION UriSAFETY-RELATED HEATING, f
VENTILATIDN AND AIR CONDITIONING ( HV A7. ) $YSTEHS IN UNIT NOS. I AND 4 CONTAINMENT 1 AND GENERAL SERV!CES SUILDINGS.. THE USE OF' THIS FORM MAS NEITHER DESCRIBED IN T v 6 PROVED QUALTTY ASSURA CE PROGRAM NOR MAS IT CONTROLLEG SY A DOCUMENTED INSTRUCTION OR N
PROCEPURE.
8102 01-26-81 01-30-81 NONCOMPLIANCEI OTHER
-INVESTIGA EE8 4
A 2927058 C
CONTRARY TO THE REQUIREMENTS OF 10 CFR 50, APPENDIX Be CRITERION y, AS IMPLEMENTED BY THE PSAR AND THE WPPSS DA PROCRAM MANUAL Q
TWO H ACeSUPPORTS WEREtFOUND'T3 CONTAIN WELD DISCREPANCIES IN EXCESS OF THOSE ALLOWED BY THE.HVAciCONTRACTOR V
PROCEDURE QAP-3, PROCEDURES AND AMS D1.1 8102
~l-26-81 01-30-81 NONC3HPLIANCE:
OTHER
-INVESTIGA EES 4
A 2927058 b
CONTRARY TO THE NEuUIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION V, AS IMPLEMENTED BY THE PS AR AND THE< WPPSS QA PROGR AM. MANNUALI J
PROCEDURE QAP-3e THREE HVAC-DUCT PLENU1S WEREIF3UND TO CONTAIN INSTALLATION DISCREPANCIES IN EXCESS OF THOSE.ALLONED BY THE.HVAC' CONTRACTOR PPOCEDURES AND AWS DI.l.
S102 01-26-81 01-30-81 NONCOMPLIANCEi OTHER
-INVESTIGA EE8 6
A 2927058 O
10 CFR 50, APPENDIX B, CRITERION 5, REQUIRES THAT ACTIVITIES AFFECTING QUALITY BE ACCOMPLISHED.AS REQUIRED BY PROCEDURES. UNSI Q
PROCEDURE QCP/CP 22.0 (CENTRAL WELDING STANDARDS) WHICH STATES, IN PARAGRAPH 7.1, THAT "THErNAME OF ALL WELDERS AND INSPECTORS..AND THE DETAILS OF INSPECTION AND ANY REPAIRS, SHALL BE RECORDED FOR ALL QUALITY CLASS I WELD JOINTS MADE UNDER THIS O
PROCEDURE AND THE REFERENC ED CODES AND STANDARDS.* CONTRARY.TO THE REQUIREM ENTS, PRIOR TO JANUARY 28e 1981, UNSI GENERALLY D 0
ID N3T DOCUMENT MELDS WHICH HAD BEEN REPATRED.
i O
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00/25/83 KPPSS INSPECT, HIS10RY-JAN 80'in PRE 8ENT PAGEl12 O
DOCMET/ REPORT INSP/ DATES FINDINGS EX CODE SEV TYPE' MODS O
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05000460 8102 01-26-81 01-30-81 NONCOMPLIANCEI OTI'ER
-INVESTIGA EJH '
4 A
2927058 O
CONTRARY TU 10 CFR 50, CRITERION 9, AS IMPLEMENTED By THE' PSAR DA PROGRAM, UNSI PROCEDURES FOR WELDING ELECTRODE CONTROL' DID NOT IMPLEMENT THE REQUIREMENTS Or AWS Dl.1 REGARDIN3 THEi DISPOSITIn*! 0F ELECTRODES WHICH HAD NOT BEEN REMUVED FROH A STCRAGE OVEN i
FOR GREATER THAN 4 NOURS.
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8604 05-20-80' 05-23-80 NONCOMPLIANCEt IN3?ECTION ROUTINE' (
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A 2490638 CONTRAPY 10 10 CFR 50, APPENDIX 8' CRITERION V, AS INPLEMENTEg isy THEtPSAR SECTION 1744.5, ONE PIPING WELD IN EACH OF TWO PIPING 3"BASSEMDLIES HAP INCOMPLETE ROOT P NETRAT10'8 04 JOINTS SPECIFIED ny DRAWING AND SPECIFICATION 10 BE plL PENETRATION WELDS.
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. INSPECTION ROUTINE'(
EEB 2
A 2490638 g
CONTRARY TU 10 CFR 50, APPENDIX 8, CRITERION Y, AS INPLEMENTED BY PSAR SECTION 17,a.5, FIVE WELDS IN FOUR PIPING SU8 ASSEMBLIES HAD INSIDE DIAMETER OFFSE!T IN EXCESS OF' TitAT ALLOWED BY SPECIFICATION AND ASMElCODE REQUIREMENTS.
8005 05-13-80 05-t5-80 CLEAR INSPECTION ROUTINEl(
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- FINDINGS, Ex CODF i SEV TYPE?
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10 CFR 50, APPENPIR R, CRITERION V, STATES, IN PARTE " ACTIVITIES AFFECTING QUALITY SHALL BE... ACCOMPLISHED IN ACCORDANCE.
WITH...INSTPUCT10r43, PROCEDURES, OR DRAWINGS...."
PARAGRAPH 17.1.5 0F THE QA PROGRAMS STATES, IN PART, IHAT " CONTRACTORS AND C
VENDUPSe INCLUDING EHASCO AND C-E, AREtREQUIRED TO HAVE' WRITTEN INSTRUCTIONS, PROCEDURES, POLICIESe ARD/OR DRAWINGS WHICH CUWL9N Q
TitEIR QUALITY RELATED ACTIVITIES...."
CONTRACT SPECIFICATION NO. 3240-2i3 FOR STRUCTURAL STEEL ERECTION REQUIRFS THAT STRUCTHRAL WELDING, A QtJALITY RELATED ACTIv!TYe BE ACCOMPLISHED IN ACCORDA"*E WITH THE AWS STRUCTURAL; WELDING CODEb Dl.l.
O PARAGRAPH 3.7 UF THIS CODE STATES, IN PART, THAT "THE' REMOVAL 0F WELD METAL OR PORTIONS OF THE BASE. METAL...SHALL BE IN SUCH A O
THE REMAINING WELD MEiALtOR BASE. METAL IS NOT NICKED OR UNDER CUT... UNACCEPTABLE PORTIONS OF,THE. WELD SHALLIBEr MANNER THAT REMOVED WITHOUT SUBST ANTI AL REMOF AL OFI THE' B AS[a MET AL.
ADDITIONAL WELD MET AL TO COMPENS ATE: FOR ANY DEFICIENCY IN SIZE SHALL BE.
D D E P t.l S I T E D.... " CONTRARY l0 THE REQUIREMENTS, AS OFIJULY 9, 1960, THE CIVIL / STRUCTURAL CONTRACTOR WORKING UNDER CONIRACT Q
SPECIFICATION 321c=263 HAD INSTALLED STRUCTURALIBEAM NO, 247 A AT UNIT 3 MITH A REINFORCING PLAIE WELOMENT aHICH CONTAINED A GROUND OUT APEA ALONG THE' FULL: LENGTH OFi THE' WELD TOE Ort A SIZE APPROXIMATELY 3/16" WIDE'AND UP TO 1/8" DELP INTO THE.3/4" O
PLATE.
ADDITIONAL WELD METAL HAD NOT BEEN ADDED TO COMPENSATE FOR THE' DEFICIENCY IN SIZE RESULTING FROM THE: GRINDING.
THIS WELD HAD BEEN INSPECTED AND ACCEPTED BY THE' CONTRACTOR'S QUALITY CONTROL DRGANIZATION, A006 06-25-80 07-18-80 NONCOMPLIANCEI INSPECTION ROUTINEt(
EPA 2
4 2480608 STATES, IN PARTE THAT MEASURES SHALL BEtESTABLISHED TO INDICATE...THE STATUS OFi INDIVIDUALi ITEMS Ori THE." NUCLE AR POWER PLANT....THESE MEASURES SHALL PRO G
10 CFR 50, APPENPIX R, CRITERION XIV, O
INSPECTIONS AND TESTS PERFORMED UP01 IPENTIFICATION OF ITEMS WHICH HAVE SATISFACTORILY PASSED REQUIRED INSPECTIONS AND TESTS, WHERE W:CESSARY, TO PRECLUDE-INADVERTENT SYPASSING OF SUCH INSPECTIONS AND TESTS...."
PARAGRAPH 17.1.14 0F'THElQA PROGRAM STAIES, IN PARTE THAT "...THE C
WPPSS OUAllTY ASSUPANCE PROGRAM REQUIRES THAT CONTRACTOR'S INSPECTION, TEST AND.0PERATING STATUS PHUCEDURES ARE WRITTEN AND SUDMITTED FOR REVIEW AND COMMENT BY THElAE.
THESE' PROCEDURES SHALL EST ABLISH ME ASURES WHICH PROVIDE FOR
"...B)
THE IPENTIFICATION OF ITEMS dHICH HAVE. PASSED REQUIRED INSPECTIONS AND TESTS, WHERE8NECESSARY, TO PRECLUDE INADVERTENT BYPAS$1NG OF O
SHCH IHSPECTIONS AND TESTS...."
CD4TLARY TO THE'REQUIRENCNTS, AS OFtJULY 9, 1980-THE CIVIL / STRUCTURAL CONTRACTOR WORKING UNDER 3
CONTRACT SPECIFICATION 3210-263 FOR STRUCTURAL S?EELIERECTION AT UNITS 3 AND 5 HAD NOT ESTABLISHED MEA 8URE8 WHICH IDENTIFY ITEMS THAT HAVE SATISFACfDRILY PASSED REQUIRED INSPECTIONS AND. TESTS SUCH THAT INSPECTIONS AND TESTS ARE'NOT INADVERTENTLY SYPASSED.
Cl THE INSPECTION OF THE BOLTED JOINT CONNECTING-STRUCIURALtBEAM NO. 77sc TO THE UNIT 3 AUXILIARY BUILDIAG WEST WALLtAT TH0 362,$-
3 FT. ELEVATION WAS REPORTED AS INSPECTED AND ACCEPTED.BY THE' CONTRACTOR'S QC PERSONNEL ON JANUARY 4e 1980 DN THE' STRUC TUR AL' S TEEL' ERECTION CHECKLIST, dHEREAS IN JULY 1980 IT WAS FOUND THAT THE JOINT WAS IMPROPERLY ASSEMBLED AND THAT THE JOINT INSPECTION HAD 7
C BEEN INADVERTENTLY RYPASSED.
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Docket /PEPORT INSP/ DATES FTNDINGS EN CODE SEV TYPE.
MUDS v)
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05000509 8009 08-29-80 09-26-80 NONCOMPLIANCE INSPECTION ROUTINE (
EDA 3
A 250073C-r) 10 CFP 50, APPENPIX R, CRITERION IV, STATES IN PART THAT " MEASURES SHALL DE' ESTABLISHED TO ASSURE.THAT APPLICAHLE REGULATORY REQHIRE"[NTS, DESIGN BASES, AND OTHER REQUIREMENTS WHICH ARE NECESSARY TO ASSUREifDEQUATE QUALITY ARE SUITABLY INCLUDED OR
('
RETERENCED IN DOCUPENTS FOR PROCUREMENT OF MATERIAL. EQUIPMENT, AND SERVICES...."
PARAGRAPH IT.t.4 0F THE QA PROGRAM AS f)
SPECIFIED In THE PSAR STATES IN PART THAT *...THE WPPSS QA PPDGRAM REQUIRES THE REVIEW AND APPROVAL OF WPPSS AND E8ASCO GENERATED PROCHPEMENT DOCUMENTS. THESE' REVIEWS VERIrY THEiINCLUSIO1 0F APPLICABLE TECHNICAL AND QUALITY REQUIREMENTS...,'
('
TABLE 3.2-1 nr THE PSAR SPECIFIES THAT THE' ENERGENCY DIE 8EL CENCRATORS AND THE' BORIC ACID MAKEUP PUMPS ARE~ QUALITY CLASS I.
CD CONTRARY TO THE REQUIPEMENTS, A9 0F SEPTEMBER 15, 1930, CONTRACT SPECIFICATION NO. 3240-251 (ENTITLED "EREC. ION OF PIPING SYSTEMS AND INSTALLATION OF MECHANICALIEQUIP9ENT*i, A WPPSS/EDASCO GENEPATED PROCUREMENT DOCUMENT, IDENTIFIED THE: EMERGENCY
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DIESEL GENEPATOPS AS QUALITY CLASS II.
AS OFtSEPTEMRER 22, 1960, THEsSAME CONTRACT SPECIFICATION IDENT!FIED THE 80RIC-ACID
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MAMEUP PUMPS AS QHALTTY CLASS II.
3:
0 8009 08-29-80 09-26-80 NONCOMPLIANCEi INSPECTION ROUTINEt(
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A 292706C-IN P ART" ACTIVITIES ArFEC ING QUALITY SHALL BE... ACCOMPLISHED IN ACCORDANCE T
10 CFR SU, APPENDIR B, CRITERION V, STATES P RAGRAPH 17.l.5 or THE QA PROGRAM AS SPECIFIED IN THE.PSAR STATES IN PART
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WITH...INSTPUCTIONS, PROCEDURES, OR DRAWINGS....'
A THAT " CONTRACTORS AND VENDORS, INCLUDING E8ASCO AND C-E~,
ARE RE9UIRED TO HAVE WRITTEN INSTRUCTIONS, PROCEDUREtPOLICIES, AND/OR nRAdlHGS WHICH COVERN THEIR QUALITY RELATED ACTIVITIES...."
C-E CONTRACT SPECIFICATION NO. 3240-02 PROVIDES FOR THE GAS DECAY
('
TANKS.
CONTRACTOR DRAdING NO. D*T6-341 ENTITLED
- GAS DECAY TAN 43,=
SPECIFIES THE'NELD SIZEe TYPE AND LUCATION FOR THE.TANWS.
- ):
CONTRARY TO THE REQUIPEMENTS, ON SLPTEMBER 10, 1980, GAS DECAY TANKS (SERIAL NOS. N2320.10 THROUGH N2320.90) EXHIBITED WELDS l
wHICH WERE UNDERSIZED, IMPROPERLY LOCATED, MISSING AND WELDS WHICH CONIAINED UNEQUAliLEC FILLETS, UNDERCUT AND INCOMPLF1E 3
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FUSION.
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8080 09-23-80 09-26-80 NONCOMPLIANCEi INSPECTION ROUTINE *(
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A 2927068 (p
to Crn 50, APPENDIX 8, CRITERION V, STATES IN PART, THAT "AC11VITIES AFFECTING QUALITY SHALL BE PRESCRIBED 8V DOCUMENTED INSTPUCTInNS, PROCEDURES, OR DRAWINGS OF A TYPEt APPROPRI ATE-To THE CgRC MSTANCES....INSTRUC TIONS, PROCEDURES, OR DRAWINGS SHALL U
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INCLUDE APPROPRI ATE Gl'ANTIT ATIVE OR QUAL T ATIVEi ACCEPTANCE' CRITERI A FOR DETERMINING THAT IMPORTANT ACTIVITIES HAVE 1>
I SSURANCE PROGRAM DOCUMENTED IN THE PSAR STATES IN PART, THAT SATI$rACTORgtY ACCowrEISHED....=
PARAGRAPH 17.l.5.Or THEtQUALITY A A EiREQUIRED To HAVE WRITTEN INSTRUCTIONS, PROCEDURES, POLICIES AND/OR R
- CONTRACTORS ANP VENDORS, INCLUDING ESASCO AND C-E,
(,*
DRAWINGS WHICH GOVERN THEIR QUAL TY RELATED ACIIVITIES AND WHICH INCLUDE APPROPRfATE QUANTITATIVE AND QUALITATIVE 1D I
ACCEPTANCE /PEJECTION CRITERIA...."
C01 TRACT SPECIFICATION NO. 3240-255, ENTITLED
- ERECTION OF PIPING SYSTEMS AND INSTALLATION OF MECHANICAL EQUIPMENT,* APPLICABLEiTO SITE WORK 8Y THE. PETER MIEWIT SONSe COMPANY, STATES, IN PART, IN PARAGRAPH 2.8 THAT (I
'RECE!VING, HANDLING AHD STORAGE OF ALL' M ATERI ALS SHALL COMPLY WITH ANSI N45.2.2-1972.
LEVELS or STORAGE.SHALL BE' DESIGNATED SY iD THE ENGINEER...."
APPENDIN 2.A-D TO THE SPEC 1FICATION INCLUDES A CHART IN PARAGRAPH 2.2 WHEREIN THE fNGINEER DES!GNATED AN H45.2.2 LEVEL 8 AS THE STORAGE LEVEU FOR THE CHARGING PUMP 3 SECTION 6. l.2 0F' ANSI N45.2.2-19 72 DEFINES STORAGE REQUIREMENTS
(-
FOR LEVEL 0 EQUIPMENT TO INCLUDE STORAGE IN AN AREA THAT IS *WELL D AINED.=
CONTRARY TO THE REQUIREMENIS, ON SEPTEMBER 23, 1p R
1990. THE PETER KIEd!T SONS' COMPANY PROCEDURE NO. PKS-WI-A10le ENTITLED, " CARE AND MAINTENANCE. INSPECTION FOR CHARGING PUMPS,*
THE GOVERNING PROCEDURE CONCERNING INPLACE STORAGE Or THE CHARGING PUMPS, DID NOT INCLUDE THE APPROPRIATE ACCCPTANCE CRIT"RIA (e
FOR A WELL DPAINED SinRAGE AREA.
FURTHEP, THE FINALt STOR AGE LOCATIONS FOR UNIT S CHARGING PUNPS NOS, 05-CH-PP-003, 004 AND 005 1p AND UNIT 3 CHARGING PUMP NO. 03-CH-PP-004 WERE NOT WELL DRAlutD IN THAT THE FLOOR DRAINS WERE PLUGGED SHUT AND THE, FLOOR 8 0F, THESE AREAS WERE COVERED WITH WATER TO A DEPTH OF ONE INCH DURING THE PERIOD SEPTEMBER 23-26, 1980.
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DOCKET /PEPORT INSP/ DATES FINDINGS EX CODE SEY TYPE NODS f)
C' 85000509 8082 10-2I-80 10*24-80 NONCOMPLIANCE' INSPECTION ROUTINE'(
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A 2927e68
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CONTRARY To THE REQUIREMENT OF THE QUALITY ASSURANCE PROGRAM AND CRITERION XV, A NQNCONFORHlNG QUALITY CL4SS I DUCT HANGER WAS DISPUSITInNEDe *USE-AS-IS," BY A SITE CONTRACTOR WITHOUT NOTIFICATION OR CONCURRENCF 0F THE' ENGINEER WHO IS RESPONSIBLEsFORTHE
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APEQUACY Or THE DCSIGN.
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8013 09-29-80 10-30-80 NONCOMPLI ANCE'
' INSPECTION ROUTINE: (
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A 248063C-()
to CFR 50, APPENDIX B, CRITERION III, STATES IN PART, THATe " MEASURES SHALL'REiESTABLTSHED TO ASSURETHAT APPLICABLE' REGULATORY REQt'IREMENT S AND THE DESIGN BASIS...AREtCORRECTLY TRANSLATED INTO...DRAMINGS..,"
PARAGRAPH 17.t.3, OF THE QUALITY ASSURANCE.
~
(i PROGRAM DOC'JMENTED IN THEtPSAR STATES, IN PART, THAT, " PRIOR TO SUBMITT AL: 0F DESIGN DOCUMENTS 10 EITNER WPPSS OR EBASCO FOR
()
REVIEW AND/UP APPROVAL, THE DEStGN CONTRACTORS, INCLUDING EBASCO, ARE RESPONSIBLE FOR VERIFYING THAT THE DESIGN NEETS THE REQt'IPEMENTS OF THE SPECIFICATIONS..."
CONTRACT SPECIFICATION NO. 3240-95 (ENTITLED, 'STRUCTUR AL' STEELI - PHASE I") SPECIFIES PROJECT SPECIFICATION NO, 3240-448 (ENTITLED " STRUCTURAL C) f THAT THE PESIGH FOR STRUCTUR.AL STEEL',SHALL'BE'IN ACCORDANCE WITH 3240-445 PARAGRAPH 2 6 STATESe IN PART, THAT, " FIELD CONNECTIONS SH ALLi BE FRICT TON TYPE. JOINTS..."
STEEL *),
SPECIFICATION NO.
AND THAT CONNECTIONS SHALL BE IN ACCORDANCE: MIT4 SPECIFICATION NO. 3240-50lWA (ENTITLED 'HIGH SIRENGTR BOLTED FIELD CONNECTIONS
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FOR STRUCTURAL STEEL *).
SPECIFICATION NO. 3210-50lWA, PARAGRAPH 6 STATES, IN PART, THAT, "J0!NIS SHALL BE FRICTION TYPEiBOLTED
)
CONNECTIONS DETAILED FOR AN ALLOWABLE WORKING STRESS IN SHEAR OF 15,000 PSI..."
CONTRARY TO THE REQUIREMENTS, ON SEPTEMBER 29, 1960, THE STEEL FABRICATOR'S DESIGN DRAWINGS FOR STRUCTURAL STEEL BEAM CONNECTIONS DETAILED JOINT CONFIGURATIONS WHICH EXCEEDED I'
TI'E 15,000 PSI BOLT STRESS LIMIT OF SPECIFICATI3N 50lWA (FOUGHT DRAdINGS NOS, 40e 41, 44, 48, 49, 206, 207, 248, 304, 34te 343,
()
AND 350) AND SPECIFIED THE USE OF BEARING TYPE JulNTS, WITH ACCOMPANYING SHEAR STRESSES OF 29,200 TO 31,900 PSI (FOUGHT DRAWINGS NOS. 40, 41, AND 11).
FURTHERMORE, THEsINSTALL1NG CONTRACTOR'S QUALITY PROGRAM DID NOT ADDRESS THE' INSPECTION OF BEARING TYPE
('
JOINTS (1.E., NO 80LT THREADS IN THElSHEAR PLRNES).
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8014 09-25-60 10=30-80 NONCOMPLI ANCE' OTHER
-INVESTIGA
. EM A
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2927058 1p 10 CFR 50, APPENPIX B, CRITERION x!I STA ES, IN PART, " MEASURES SHALL BE ESTABLISHED TO ASSURE THAT TOOLS, GAUGES, INSTRUMENTS, T
AND OTHER ME ASURING AND TESTING DEVICES ARE'... PROPERLY...C ALIBRATED... AT SPECIFIED PERIODS...* -PARAGRAPH IT.4.12.1.A 0F'THE SYST N QUALITY ASSURANCE' PROGRAM DOCUMENTED IN THE PSAR STATES, INPART, THAT, "... SITE CD
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WASilINGTON PUDLIC P0 DER SUPPLY E
CONTRACT 0PS' APPROVED PROCEDURES ESTA9LISif A SYSTEM FOR THE CONTROL, CALIBRATION AND ADJUSTMENT OF'TOOLB, GAUGES, INSTRUMENTS AND OTHER INSPECTION, MEASURING, TESTING AND MAINTENANCEIDEVICES USED AT THE SITE.
THIS SYSTEM IS ESTABLISHED SUCH THAT CE CONFORMANCE TO ESTABLISHED REQUIREMENTS IS VERIFIED AT SPECIFIC PERIODS OF TIMEiTO ASSURE THE USAGE;DF PROPER TYPE, RANGE.AND
[p O P-8-10, REVISION 2, DF THElSITE HVAC' CONTRACTOR, WALLACE/ SUPERIOR, STATES, IN PART, ACCtRACY OF THE PEWICE."
PROCEDURL.NO.
C RECORDS SHALL BE R VIEWED AT THE'BEGINNING OF EACH HONTH BY THEPROJECT QUALITY ASSURANCE HANAGER/ DESIGNEE.."
"ALL CALIRRATION E
II CD NTPARY TO TIIE REQUIREMENTS, ON SEPTEMBER 25, 1960, THE' WALLACE/ SUPERIOR C ALIBRATION RECORDS HAD NOT REEN REVIEWED BY THE
()
PROJECT QUALITY ASSURANCEiMANAGER OR DESIGNEElSINCEtJULY I, 1980 FURTHERMORE, THEL CALIBR ATION RECURDS FOR FIVE PIECES OF.
ENUIPMENT DOCUMENTED THAT THE EQUIPMENT HAD NOT BEEN RECALLED AND RECALIBRATED WITHIN THE DATES SPECIFIED ON THE' CALIBRATION
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A 2480618 f) 10CFR 50 APPENDIX R, CRITERION V, AS I9PLEMENTED BY SECTION 17 4 5 0F' THE QUALITY ASSUR ANCE PROGR AM DUCUMENTED IN THE APPROVED Pi AP PE VI ATION 18-hP, STATES, IN PART, THAT " ACTIVITIES AFFECTING QUALITY SHALL BElPRESCRIBED BY DOCUMENTED INSTRUCTIONS, F'
PROCEDURESe OR DRAWINGS, OF A TYPE AFPROPRIATE TO THE'CIRCU4 STANCES AND SHALL BE' ACCOMPLISHED IN ACCORDANCE WITH THESE-C) l INSTRUCTInNS, PPOCED'JRES, OR DRA WINGS."
CONTRACT SPECIFICATION NO. 3240-265, " REACTOR SUILDING CONCREIE CONSTRUCTION", THE GOVERNING SPECIFICATION FOR THE' CONTRACTOR'S (J.A. JONES CONSTRUCTION COMPANY) WORK ACTIVITIES UN THE' RE ACTOR BUILDING, STATES
" CONTRACTOR SH LL SU8MIT THE' ORIGINAL'COMPLE(ED NONCONFORHANCEaREPORT WITH Op A
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IN PAPAGRAPH I4.6.1 THAT FOR NONCONFORMANCEIREPORTS, E GINEER'S QUALITY ASSURANCE. SITE SUPERVISOR. PARAGRAPH APPLICABLE SUPPORTING ENGINEERING AND INSPECTION DOCUMENTATION TO N
14.6.6 STATES THAT, "FOR NRB REVIEWED NONCONFDRMANCES, ENGINEER SH ALL' ALSO WITNCSS THC RE-INSPECTION, DETERMINE'ITS (T
ACCEPTARILITY AND SIGN OFFrTHE NONCONFORMANCEtREPORT AFTER PRIOR CONTRACTOR INSPECTION AND APPROVAL,*
CONTRART TO THE (D
REQUIPEMLHTS, THE J.A. JONES CONSTRUCTION COMPANY PROCEDURES AND RELATED WORK PRACTICES DID NUT INCORPOR ATE THE' SPECIFIC ATION REQUIREMENTS OF NOTIFICATION TO AND WITNESSING OF REINSPECTIONS BY THEiENGINEER.
[HIS PROCEDURE WAS APPROVED FOR USE BY THE 13 CONTRACT 0P AND THE ENGIN((R.
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GI 8015 11-18*80 81-21-80 NONCONPLIANCEI INSPECTION ROUTINEt(
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2927028
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10 CFR 50, APPENDIX 8, CRITERION V, AS IMPLE.1ENTED BY SECTION 87.4.'5. OF THE QUALITY ASSURANCE PROGRAM DOCUMENTED IN THE.
APPROVED PSAP DEVIATION 88-WP, STATES, IN PART, THAT " ACTIVITIES AFFECTING QUALITY,.,SHALL BE ACCOMPLISHED IN ACCORDANCE.
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WITH... INSTRUCTIONS, PROCEDURES OR DRAN NGS."
SPECIFICATION NO, 324C-ge TITLED " PIPING AND PIPING SUPPORTS"MPP85 QUALITY CLAS8
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I 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 ASNE SECTION III" ANO FURTHER STATES IN PARAGRAPH 6.010-III THAT "THE ENDS OF THE PIPE-TO-PIPE, PIPE-TO-FITTING,
(*
AND PIPE-TO-VALVE JOINTS SHALL BE AL1GNED AS ACCURATELY AS PRACTICAliWITHIN THEiEXISTING COMMERCIAL CODES AND STANDARDS
{
TOLERANCE OF PIPE DIAMETERS, PIPE WALL' THICKNESS, AND OUT-Or-ROUNDNESS."
THE ASME;BAPV CODE, 1974 EDITION, SUMMER 1976 ADDENDA 6 SUBSECTION NCe TABLE NC-1232(A)-l SPECIFIEP A MAXI 9UM ALLOMADLE OFFSET IN FINAL WELDED CIRCUHFERENTIAL JOINTS OF 1/4 i NHENE T
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IS THE NOMINAL THICKNESS OF THE THINNER SECTION AT THE JOINT AND IS LESS THAN OR EQUAL TO 1/2 INCH, CONTRARY TO THE
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REQUIPEMENTS, ON NOVEMBER 19, 1980 AT THEiSAGINAW STORAGE' AREA, CIRCUMFERENTIAL' SHOP MELD "A* DN PIPING SUSASSEMBLY NO, 3-2CH-20-150-2 HAD A FIVD (5) INCH LONG AREA 0F# INTERNALIDFFSET MEASURING 3/16 INCH, THIS OFFSET IS Iw1CE THE AFUREMENTIONED
(*
CODE ALLOWAnLE MAXIMUM OFFSET OF 3/32 FOR THIS THICKNESS PIPE' (4375 INCH),
THIS PIPING HAD BEEN ACCEPTED BY THE. SITE RECEIVING Q)
INSPECTION ORGANIZAfl0N.
8086 10-31-80 12-04-80 CLEAR INSPECTION ROUTINEl(
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05000505 8037 32-09-80 12-19-80 NONCOMPLIANCEI INSPECTION ROUTINEI(
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4 292706C' f) 10 CFR So APPENDIX R, CRITERION IX, STATES, IN PART, THAT, ""EASURES SHALL BE ESTABLISHED TO ASSURE THAT SPECIAL PROCESES, INCLUn1NG "ELDINGe...ARE CONTROLLED AND ACCOMPLISHED BY QUALIFIED PERSONNEL USING QUALIFIED PROCEDURES IN ACCURDANCE WITH
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APPLICA8LE CONES...*
PARAGRAPH 17.0.9 0F' THE' 0'JALITY ASSURANCE PROGRAM DOCUMENTFD IN THE PSAR STATES, IN PART, THAT C)
...PEPSONNEL PERFORMING SPECIAL PPCCESSES AT 19E CONSTRUCTION SITE WILL BE QUALIFIED AS REQUIRED BY THE APPLICABLE CO SPECIF1ES TH T THEfAWS 0I.1 STRUCTURAL-WELDI4G CODE'IS THE APPLICA8LElCODE FOR A
STANDARDS..."
CONSTPUCTION CONTRACf 40, 3210-232
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STRUCTURAL WELDING, INCLUDING QUALfr* RATION. FIDORg.5.27 0F.THE AWS CODE IDENTIFIES THE CONFIGURATION OF THE GUIDED-BEND TEST (D
JIG TO nE USEn IN TESTING WELDER QUnll/ICATION TEST COUPONS. THE FIGURE SPECIFIES THAT FOR HATERIAL MITH A VIELD STRENGTH OF LESS THAN 50,000 PSI THE PLUNGER AND INTERIOR DIE RADII SHALL BE 3/4 AND l-3/16*, RESPECTIVELY, CONTRARY TO THE.REQUIRENENTS, (4
ON DECEMBER 16, 1980, IT dAS FOUND Thai THEiSITE.HVAC CONTRACTORS (CONTRACT 3240-232) HAS BEEN QUALIFYING WEL0ERS USING AN
()
IMPROPERLY SIZED GUInED-8END TEST J!G.
WELDERS WHO HAVEtBEEN MANING QUALIFICATION TEST COUPONS WITH ASIM A-36 MATERIALI(YIELD STRENGTH nF APPROX 11ATELY 36,000 PSIf MAVE*BEEN QUALIFIED BASED ON TESTING WITH A JIG HAVINC PLUNGER AND INTERIOR DIE RADII 0F,
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l' AND l-7/16", PESPECTIVELY.
(F Slut 01-13-81 01-16-81 NONCOMPLIANCEt INSPECTION ROUTINEl(
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4 2927068 C) 10 CFR 50, APPENDIX 9, CRITERION V, AS IMPLEMENTED BY SECTION 17.4.5 0F THE' QUALITY ASSURANCE PROGRAM DOCUMENTED IN THEIAPPROVED PSAR PEVIATION lO-mP, STATES, IN PART THAT " ACTIVITIES AFFECTING QUALITY...SHALL BEiACCOMPLISHED IN ACCORDANCE II WITH... INSTRUCTIONS, PROCEDURES OR DRAWINGS.*
MOURISON-KNUDSEN ADNINISTRATIVElINSTRUCTION PROCEDURE. NUMBER 15, eSTUD WELDING
()
INSPECTION rFPCEDURE," STATES IN PARAGRAPH 6.3 THAT, "EACH OPERATOR SHALL BEND THE FIRST TWO STUDS ON EACH DAY'S PRODUCTION TO 30 DEGREES 4ND THE FIRST TWO STUDS ON E'ACH MEMBER TO 30 DEGREES," IN PARAGRAPH 6.8 THAT, *THE OPERATOR SHALLtCIRCLEsWITH A PAINT
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STICK, OR PAINT A LINE UP THE SHANK OriTHE'FIRST TWO STUDS BENT ON EACH NEW MENBER,a 4%D IN PARAGRAPH 6.5 THAT, 'ALL FERRULES dD THE PRIOR TO< INSPECTION.*
CONTRARY TO THE REQUIREMENTS, ON JANUARY I4, 1981, ON THE'SOUTHSIDE 362','0PERATORTHE INSPECTORS OBSERVED THE FOLLOWINGt (l) A STUD WELDING OPERATOR WELDING ON A MEMBER BETWEEN MHST BE DROMEN OFF RY OF UNIT 5 ELEVATION (I
NOS. CA-12 ann CA-13 HAD WELDED APPROXIMATELY SIXTY STUDS WITHOUT RENDgNG THE FIRST TWO STUDS.
(2) A NUMBER OF STUDS WERE FOUND d$
WHICH WEPE DENT, BUT HAD NOT RECEIVED THEiNECESSARY PAIRT MARK, IT WAS LATER DISCOVERED THAT THE' QUALITY CONTROLt INSPECTOR HAD BEEN MARKING THE STUDS, NOT THE OPERATOR. THIS SECOND ITEM HAD BEEN OCCURRING FOR AN INDETERMINATE' TIME IN BOTH UNITS 3 AND 5.
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(5) NUMER'WS STUDS WERE FOUND WITH PARTS OFeTHEIFERRULES STILL*IN PLACE, THESE STUDS HAD BEEN INSPECTED AND ACCEPTED BY THEi dp WORRISON-KNUDSEN QUALITY CONTROL INSPECTOR.
1D
(
8102 01-05-81 01-30-89 NONCOMPLIANCEt INSPECTION ROUTINEf (
EEA 2
A 248063C' 10 CFR 50, APPENPIX 6, CRITERION V, STATE 3e IN PAPT THATe " ACTIVITIES AFFECTING QUALITY SHALL BE PRESCRIBED BY DOCUMENTED
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INSTRUCitnHS, PROCEDUPES, OR DRAWINGS, OFiA TYPE APPROPRIATE TO THE CIRCUMSTANCES AND SHALL BE ACCOMP6ISHED IN ACCORDANCE.WITH
()
THESE INSTRUCTIONSe PROCEDURES, OR DRAWING." PARAGRAPH 17 l.5 0F THE WPPSS GA PROGRAM, AS DOCUMENTED IN THE'PSAR, STATES, IN S
"...CONTRAC ORS...ARE RE3UIRED TO HAVE WRITTEN INSTRUCTIONS, PROCEDURES, POLICIES, AND/UR DRAWINGS WHICH GOVERN THEIR T
PART THAT,
(?
UUALITT-RELATED ACTIVITIES AND WHICH INCLUDE' APPROPRIATE QUANTITATIVEiAND QUALITATIVE ACCEPTANCE / REJECTION CRITENIA...,"
()
PARAGRAPHS 3.R 5.6 ann 3.8.3.6 0F THE WPPSS PSAR SPECIFIES THAT CONSTRUCTION WILL BE PERFORMED IN ACCURDANCE'WITH THE'AMER THE! AME IC AN N ATION AL ST AND ARD ANSI N15.2.5, P AR AGR APH 5.4, STATES, IN PART THAT,
'...ALL R
NATIDHAL STANnAPP ANSI H15.2.5.
(T CONNECTION POINTS FHALL BE VISUALLY INSPECTED FOR THE FOLLOWING ITE SI 1 ROLTS ARE THE CORRECT iENGTH... CORRECT TYPErBULT IS
()
M S RUCTURAL STEEL ERECTION REQUIRES THAT BOLTING OE PERFORMED T
USED...dASHEPS ARE USED dHEN RgQUIRED...."
CONTRACT 3240-263 FOR l
IN ACCORDANCE WITH THE AMERICAN NATIONAL STANDARD ANSI N15.2.5 CONTRARY TO THE REQUIREHENTS, IHE 3240-263 CONTRACTOR'S IMPLEME TED PRIOR TO JANUARY 28, 1981, REQUIRED TNSPECTION DF ONLY 203 UR TWO 80LTS PER
()
N (D
APPPOVED PROCEDHRE, WHICN HAD BEEN CONNECTION PDIHT.
THIS PROCEDURE IS INAPPROPRIATE IN THAT IT PRESCRIBES INSPECTION REQUIREMENTS LESS THAN THOSE.SPECIF1ED IN 4
THE CONTRACT SPECIFICATIONS AND ANSI N45.2.5.
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i rs e) 09/25/R1 WPPS1 INSPECT, HISTORY-JAN 90 TO PRESENT PAGEi18 EXCLUDES 2.790 INFORMATION 70CMET/ REPORT INSP/ DATES FINDINGS EX CODE SEV TYPE MUDS
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05000509 8502 01-05-88 01-30-81 NONCOMPLIANCE' INSPECTION ROUTINE (
EEB
/
A 248063C
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le CFP 50. APPENDIX B,
CRITERION V,
STATES, IN PART THAT, " ACTIVITIES AFFECTING QUALITY SHALL BE PRESCRIPED BY DOCUMENTED INSTRUCTIONS...AND SHALL PE ACCOMFLISNED IN ACCORDANCE WITH THESE INSTRUCTIONS...,"
PARAGRAPH 17.4.5 0F THE'GA PROGRAM C'
DOCV"ENTEP IN THE PSAP STA4ES, IN PART THAT, " PROVISIONS ARE MADE FOR ASSURING THAT ALL QUALITT-RFLATED ACTIVITIES ON
()
S TRUC TURE S...aRE PERFOPHED IN ACCORDANCE WITH APPROVED INSTRUCTIONS...."
APPROVED CONTRACTOR INSTRUCTION NO, AT-le-NPPSS (COHTRACT NO. 3210-263) REQUIRES THAT ALL STRUCTURALtWELDS ON QUALITY CLASS 1 STRUCTUR AL STEEL BE' INSPECTED AND THE INSPECTIONS
(?
DOCU 9E N T E D ON AN INSPECTION REPORT (FORM QC=19).
CONTRARY TO THE REQUIREMENTS, UN JANUARY 21, 1981, THE9E WAS NO INSPECTION CD REPHRT FOR A UtiTT 3 STRUCTURAL STEEL: WELD CONNECTING THE BEAM CLIP FOR GEAM 237F' TO THE EMBED PLa f f.
A STRUCTURAL STEEL CHECKLIST, DATED APRIL 28, 1960, INDICATED THAT THD CONTRAC TOR HAD ACCEPTED THIS PDRTION OF THE 3 *<ttuRE.
Il CD 8102 01-05-81 01-30-51 N04C04PLI ANCE' INSPECTION ROUTINEt (
EKA 2
A 246063C (5
10 CFR 50. APPENPIX B, CRITERION x, STATES, IN PART THAT, "A PROGRAM FOR INSPECTION OF ACTIVITIES SHALL:BE ESTABLISHED AND
[)
EXECUIED...TO VERIFY CUNFORMANCE wlTH THD DOCUWENTED INSTRUCTIONS, PROCEDURES, AND DRAWINGS FOR ACCUMPLISHING THE ACTIVITY....'
PARAGRAPH 17.4.10.3 0F<THE WPPSS QUALITY ASSURANCE. PROGRAM AS DOCUMENTED IN THE'PSAR, STATES, IN PART THAT, ' SPECIFIC CONTRACTOR
('
INSPECT 10NS ARE TO BE PERFORMED FOR V[RIFYING CONFORMANCE'TO CONTRAC.T REQUIREMENTS...AND ACCEPTABILITY OF. MATERIAL.AND EQUIPMENT 1)
WHICH HAVE DE Ell INSTALLED AND ERECTED ON THElCONSTRUCTION SITE ARE IN ACCORD ANCE WITH APPROVED SITE CONTR ACTOR PROCED'JRES...."
APPROVED SITE CONTRACTOR (3240-263) PROCEDUPEt N3. CP-05 REQUIRES TH AT BOLTING BE' PERFORMED IN ACCORD ANCE' WI TH APPROVED. EREC TION
{'
DRAWINGS AND THAT PLATE OR BAR-TYPE WASHERS BE USED ON THE OUTER PLY OF JOINTS HAVING LONG SLOTTED HOLES.
ERECTION DRAWING NU.
()
G-3435 DESIGNATES THAT WASHERS SHALLt9ElUSED FOR ANCHOR BOLilNG COLUMNS. CONTRARY TO THE. REQUIREMENTS, ON JANUARY 21, 1981, THE BOLTS CONNECTING UNIT 3 8EAMS 235E AND 237D TO THE WALL' CLIP WERE NOT EQUIPPED WITH PLATE OR BAR WASHERS UVER THE LONG SLOTTED
('
HOLESI UNIT 3 CULUMN NO. 12A HAD BEEN ANCHOR BOLTED WITHOUT THE USE' 0F WASHERS p AND UNIT 5 CONNECTIUN OF BEAM 43C'TO COLUMN 419A
()
CONTAINED UNE HOLT WITHOUT THE REQUIRED WASHER.
CONTRACTOR QUALITY RECORDS INDICATED THAT THIS 80LilNG HAD BEEN PREVIOUSLY INSPECTED AND ACCEPTEP nY THE CONTRACTOR'S QUAL 1TY CONTROLtSTAFF.
8802 01-05-61 01-30-88 NONCOMPLIANCEI INSPECTION ROUTINEl(
ETB 3
A 246063C C
le CFR 50, APPENPl*
H, CRITERION xWII, STATES, IN PART THAT, =SUFrICIENT RECORDS SHALL RE MAINTAINED TO FURNISH EVIDENCE 0F' (p
ACTIVITIES AFFECTING QUALITY... INSPECTION AND TEST RECORDS SHALL, AS A MINIMUM, IDENTIFY THE INSPECTON OR DATA RECORDER...."
PARAGPAPH 6.7 UF CONTRACT 3240-263, PROCEDURD N3. CP-05 (ENTITLED, "STRUCTURALiSTEEL ERECTION") REQUIHES THE DEVELOPNFNT OF
' AS-n lLT* OPAwiNG RECDPDS FOR STRU TUR AL< STEELL CONNECTIONS AND REQ'JI ER S THAT EACH CONNECTION SHALL BE VERIFIED AS COMPLETE RY 1)
(?
u C
SIGNIF)ING WITH (QC) INITIAL OR STAMP FOR THAT CONNECTION. FURTHER, TH
E. PROCEDURE
REQUlHES THE. DOCUMENTATION OF. BOLTING INSPECTIONS ON INSPECTION REPORT FORM NO. QC-19 FIR.
THIS FORM INCLUDES AN AREA TO IDENTIFY THE' SPECIFIC ITEMS INSPECTED.
U?
CONTRARY TO THE REQUIREMENTS, ON JANUARY 28, 1951, THE.FULLOWING R[ CORD DTSCREPANCIES WERE IDENTIFIED (1) THE COMPLETED 1p AS-DUILT DRAn!HG FOR UNIT 5 STRUCTURAL! STEEL ASSOCIATED WITH CoaCHETEePLACEMENT NO. 5A83-010-162 CONTAINED NO VERIFYINGiINITIALS OR INSPECTION STAMPS.
(2)
QC-19 FIR NO. 5-38-42 DAT D NOVEM0ER 6, 19R0 INDICATED EIGHT BOLTS WERE INSPECTED IN EACH UFlFOUR E
('
CONNECTIUNS (Two NUMHERED 270F"260A AND TWO NUMRERED 270F-262A) WHEN, IN FACTe THE: DESIGN DRAWINGS AND ACTUAL' INSTALLATION
()
CONTAINED UNLY FOUR BOLTS PER CONNECTION. SIMILARLY, CONNECTION NO, 25tF-24TE6263C NAS REPORTED TO HAVE 14 BOLTS, WHEN ONLY 12 WERE RERUIRED AND INSTALLED. (3) A QC=lgFIR FORM COULD NOT BE LOC ATED FOR THE INSPECTION OF 00LTING ON UNIT 3e COLUMt NO. 12Ap
()
ALTHOUGH, CONTRACTOR REPRESENTATIVES REPORTED THIS BOLTING COMPLETF AND ACCEPTED IN MARCH 1980
(),
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8103 02-25-81 02-25-61 CLEAR INSP[CTION MANAGEMEN C)
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8105 03-10-81 03-13-81 CLEAR INSPECTION ROUTINE'(
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O 8106 03-23-81 03-27-81 CLEAR INSPECTION R(IUTINE: (
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f 8107 03-02-81 03-21-88
'40Nr0MPLI ANCEF IN3PECTION ROUTINE: (
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4 255063C>
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to CFft 50, APPENotX H, CRITERTON IX, STATES IN PARTI "ME ASURES SHALLt DE EST ABLISHED TO ASSURE THAT SPECI AL PROCFSSES, INCLUDING MELDING... APE CONTROLLED AND ACCOMPLISHED...USI'4C QU LIFGED PRUC[DURES IN ACCORDANCEtWITH APPLICARLE CODES, STANDARDS, A
f SPECIFICATIONS, CRITERIA, AND OTHER SPECIALIREQUIREMENTS." P A R A f;R A p H 17.1.9 Ori THE. QUALIT Y ASSURANCE PROGRAM DOCUMENTED IN THE PSAR STATES IN PART:
"...SPECIAL P7UCEDURES PREPARED BY SITE'CONTRAC ORS dILLsBE QUALIFIED MHEN REQUIRED IN ACCURDANCEIMITH T
APPLICABLE CODES AND STAHDARDS.......'
THElELECTRICAL INSTALLATION CONTRACT SPECIFICATION (NO, 3240-225/253) SPECIPIES THAT ACCO DANCE WITH THEL AMS STRUCTURALIMELDING CODE DI.I.
THE.
O C
ELECTPICAL CADLE TRAY SUPPORT dELDING SH ALL' BE ACCOMPLISHED IN R
STRUCTURAL WELDING CODE STATES THAT PAOCEDURES MUST BE QUALIFIE0 UNLESS CERTAIN PEQUIREMENTS ARE MET, AMONG THESE REQUIREMENTS ARE IH4T F'LLET WELDS MUST "fET MINIMUM SIZE REQUIREMENTS FOR VARIOJS BASE HETAL' THICKNESSES. F UR ER AMPLE, FOR RASE'HETALS C
THICKER THA.: 3/4 INCH THEtMINIMUM FILLET WELD SITE' IS 5/86 INCH.
THEtELECTRICAL EARLE TRAY SUPPORI DNAWINGS (E.G., DWG. NO.
SS-27 FOR SHPPUPTS E-162 THROUGH E-165) DESIGNATE 3/16 INCH FILLET dELDS FOR BASE' MATERI AL THICRNESSES OF 1.26 INCHEB, IN ADDIfl04, APPROVED FIELD CHANGE REQUEST NO. FCR-F-10 t? 0F J ANUARf 31. 1981, FOR CONTRACT NO. 3240-225/253, SPECIFIES THti THE C
CONTRACT 0P'S,le.LET dELD PROCEDURE MUST BE-QUALIFIED. CONTRARY TO THE REQUIREMENTS, AS OF HARCH 26, 1988, THE CONTRACTOR HAD NOT QUAlIFIEn etl2 FILLET dELDING PROCEDURE, YET HAD USED THIS PROCFDURE FOR THE' WELDING UF' ALL S AFETy=REL ATED C ABLE TR AY SUPPOMTS.
V 880A 01-83-81 04-23-81 NONCOMPLIANCEI INSPECTION ROUTINE (
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10 CFR 50, APPENDIX R, CRITERION VI, STATES, IN PART: 'HEASURES SHALL BE ESTABLISHED TO CONTROL THE ISSUANCE OF DOCUMENTS, SUCH AS I NSTRUC T illN S, PROCEDURES, AND DRAWINGS, INCLUDING CHANGES THERETO, WHICH PRESCRIBEiALL ACTIVITIES AFFECTING QUALITY.
THESE MEASURES SHALL ASSURE THAT DOCUMFNTS, INCLUDING CHANGES,..ARE DISTRieUTED TO AND USED AT THE LOCATION WHERE THE PRISCRIBED Q
ACTIVITY IS PERFORMED..."
PARAGRAPH 17.2.6 0F THE QUALITY ASSURANCEtPROGRAM STATES, IN PARTI "... APPROVED CHANGES AREIPROMPTLY INCLUPED "88EPE APPLIC A8LE INTO IN3TRUC.TIONS, PROCEDURES, DRAWINGS, AND OTHER APPROPRIATE' DOCUMENTS.e00SULETE OR SUPERSEDED DERTENT USEt...*
CONTRARY TO THE REQUIREMENTS, AS OF APRIL 16, 1981, THE EBASCO SITE DOCU*ENTS ARE CPNTROLLED TO PREVENT INA V
(*
SUPPUPT ENGIN(( RING ([3S[) GRQup HAD NOT ESTABLISHED MEASURES TO ASSURE THAT APPROVED CHANGES TO DOCUMENIS ARES DISTRIBUTED AND 09ED.
SEVEN DRAWINGS dERE IDENTIFIED IN ESSEtCONTROLLED FILE NO. R-15 WHICH DID NOT INCLUDE APPROVED CHANGES THAT APPL 2ED TO THESE DRAdINGS (WPPSS/EBASCO DRAntNGS 3210-G-2520-BI, 2520-S2 25213 2539p 2550s 1300-43 AND 1325).
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DOCMET/REFORT INSP/ DATES FINDINGS EX CODE SEV TYPE M008
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0530050m 8108 01-13-81 04-23-81 NONCOMPLIANCEe.
INSPECTION ROUTINE (
EER S
A 2480648
- )
SPECIFICAIION HO. 3240-112. " FORMED CONcRE E CONSTRU TIONe* PARAGRAPH 5.02, SPECIFYING QUALITY RELATED REQUIREMENTS F04 PLACING T
C AND FIELD l'ENDING REINFORCING STEEL, ST ATES, IN PART:
"...REHAR SHALL BE COLD BENT USING PROPER BAR BENDING EQUIPMENT AND THE-f.
DIAMETEP DF THE DEND *EASURED ON THEiINSIDE'0F THE.BAR SHALL NOT BE LESS THAN THE.FDLlodIMs...
84R SIZE, NOS. 3 THRU 8, NOS.
f) 9e 10, 11 MINIMUM DIAMETERS, 6 BAR DIAMETERS, 8 BAR DIA"ETERS.... RESPECTIVELY* CONTRARY TO fHESE GOVERNING INSTRUCTIONS, ON APRIL 27, 19R1, THE REINFORCING BAR BENDING EQUIPMENT, UTILITED BY MORRISON-KNUDSEN FOR FIllD BENDING OF SAFETY-RELATED (T
REINFORCING STEEL, H40 0ENDING PIN SIZES WNICH RESUL1ED IN A REND 'NSIDE DIAMETER SHALLER THAN IHOSE HEQUIRED BY THE
()
I SPECIFICATION, FOR RAR SIZES 4,
5, 6,
8, 10, AND lit Bf ABOUT 1.3 BAR DIAMETERS FOR NO. 4 BARI 2.24 OAR DI AMETERS F OR NO. 5 BAR: 1.9 BAR DI AMETERS FOR NO. 6 B arf 1.25 BAR DIAMETERS FOR NO. 8 BAR 3 BAR DIAMETERS FOR NO. 10 BARF AND 3 BAR DI AME.TE RS FOR (T
NO, 11 BAP.
f).
(D 8108 04-13-81 04-23-81 NONCOMPLIANCEt INSPECTION ROUTINEl(
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A 2551548 dp MORRISDN-ENUDSEN ADMINISTRATIVE. INSTRUCTION PROCEDUR' NUMBER 15, "STUG MELDING INSPECTION PROCEDURE,* INCLUDES QUALITY TEST.
E INSTRUCTIONS WHICH STATE IN PARAGRAPN 6.3 THAT, 'EACH OPERATOR SHALLIBEND THE FIRST TNG STUDS ON EACH DAV'S PRODUCTION TO 30 II DEGREES AND THE FIRST TWO STUD,S ON EACH MEMBER To 30 DECREES.= CONTRARY TO THElREQUIREMENT, ON APRIL'15, 1951, ON THE SOUTH CD '
SIDE OF UNIT 3, ELEVATION 417, THE INSPECTOR 03 SERVED THAT A Stun dELDING OPERATOR WELDING UN A MEMBER (NUMBER D1338) HAD MELDEP 24 Stuns MITH0HT BENDING THE FIRST TWO STUDS.
8 ton 01-13-81 04-23-88 NONCOMPLIANCEI INSPECTION ROUTINEtt EES 4
.A 2480648 3210-G-3357, WHICH GOV RNS STRUCTURALtSTEEL BEAM FABRICATION, SHOWS THAT STIFFENER PLATES ARE: COPED OR dp -
(
EHASCO DRAdING NO.
E CLIPFED AT THE REAM WEB AND FLANGE' INTERSECTIONS AND TH AT FILLET WELDS TERMIN ATE THE. COPED EDGEI DF THE STIFFENER PL ATE.
CONTRAPY TO THE REQUIPEMENT, ON APRIL 20, 1981, MOST OF'THEt SilFFENER PLATE' WELDS ON STRUCTURAllBEAMS NUS. 01190, D354, 063A,
(*
D64n, F185, F69F, FilR, A258, 3184, 3088, AT A SITE' STORAGE AREA, DID NOT TERMINATE AT THE CUPED EDGE OF ThE; STIFFENER Pt.ATES,
()
Bui COHilHUED 1HROUGH THE COPED AREAS.
THESEtBEAMS HAD BEEN PREVIOUSLY INSPECTED AT THE FABRICATION SHOPS AND ACCEPTED.
8 ten 01-13-81 04-23-81 NONCOMPLTANCEt INSPECTTON ROUTINEt(
EHA 6
A 235061B ADMINISTRATIVE SITE PROCEDURE ASP-CN-4-lT, REWISION 0, (ENTITLED
- CARE AND ISSUE 0F'MCASURING AND TESIING EQUIPMENT'), IN EFFECT REVISION 0 (INTEHIM) (ENitTLED " CARE AND ISSOE Ori (p
SI TE', PROCEDURE PSP-MM-ll-9, PROVIDE: DET AIL INSTRUCTIONS ON THE. CARE, HANDL
(
FROM MARCH 20, 1990, TU MARCH 3, 1981, AND PROJECT 3 19814 MEASURING AND TEST EQUIPMENT *),
IN EFFECT SINCEIMARCH OF CAL!bMATED EQUIPMENT USED TO PER ORN QUALITY CHECKS, ROTH OF'THESE PROCEDURES STATE, IN PART,
"...AT NO TIMO IS MEASURING F
(-
AND TEST EQUIPMENT TO BE ISSUED WHUt ANY DAMAGE'IS SUSPECTED..."
CONTRARY 70 THE REQUIREHENTS, CALISHATED TORQUE MRENCH (SERIAL
()
NO. 33748) MAS R THRNED TO THE. CALIBRATION STORAGE' AREA ON DECEMBER 22, 198G, WITH A NRITTEN STATEMENI INDICATING IT WAS DAMAGED, PEQUIHING REPAIR.
04 MARCH 6, 1981, THE. WRENCH HAD NOT REEN REPAIRED BUT WAS ISSUED FOR USE AND WAS USED TO CHECK THE
(
TORQUE OF 00LTS ON A REACT 01 COOLANT PUMP MOTOR SUPPORT, AS OF* APRIL' 16, 1981, THEtWRENCH IURQUEtGAUGE STILL HAD A BROKEN CLASS Q).
AND BENT INDICATING NEEDLE.
L-Q>
8109 05-12-81 05-15-81 CLE%R INSPtCTION RJUTINEl (
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0 05000509 8110 05-04-81 06-02-81 NONCOMPLIANCEI INSPECTION ROUTINEi(
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A 250090C' O
10 CFR 50, APPENDIR B, CRITERION III, STATES, IN PART, THATI
- MEASURES SHALL BE ESTABLISHED TO ASSURE THAT APPLICABLE REGULATORf PEQitIREMENTS AND THE DES GN BASIS...ARE CORRECTLY TRANSLATED INTO... DRAWINGS..."
PARAGRAPH 11.l.3 0F THE QUALITY I
C A SSt'R ANCE Pp0 GRAM DOCUMENTED IN APPROVED PSAR DEVIATION NO. 26-WP, STATES, IN PART, THAT: "... PRIOR TO SUBMITTAL-(UF DESIGN O
DOCUMENT) 70 EITHER =PPSS OR EBASCO FOR REVIEW AND/0R APPROVAL, THE DESTGN CONTRACTORS, INCLUDING EBASCUe ARE RESPONSIBLE FOR VERIFYING THAT THE DESIG4 MEETS IHE REQUIREMENTS OF'THD SPECIFICATION...."
THE' PS AR, SECTION 3.2, PROv t DES F OR S AFE TY-REL A TED O
ASME PIPE SUPPORTS TO BE DESIGNED 11 ACCORDANCE WITN THD ASME BOILER AND PdESSURD VE8SEL' CODE, SECTION III.
SECTION III, Q
APPENDIt XVII, PARAGRAPH 2452.1 SPECIF1ES THE' 11NIMUM ALLOWABLE FILLET MELD SIZES FOR VARIOUS THICKNESSES OF WELDED CONNECTIONS ON PIPE SUPPI)RTS.
CONTRARY TO THE REQUIREMENTS, 04 MAY 29, 1981, II WAS DETERMINED THAI CONTRACTOR DESIGN DRAWINGS FOR ASME O
SAFETT-RELATED PIPE SUPPORTS NO. 3G-CH-I35 (ONEiWELDi, 3G-CH-163 (TWO WELDS), AND 3G-CH-267 (ONE WELD) SPECIFIED MELDS SMALLER Q
THAN THE MINIMUN SIZE PERMITTED BY THEt ASMEt CDDE' SECTION ITI. 8.PPE N D I X XVTI, PARAGRAPH 2452-1.
Sito 05-08-81 06-02-81 NONCOMPLI ANCD INSPECTION RUUTINEl(
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...SPECIAL PROCESSES, INCLUDING MELDING...ARE CONTROLLED AND 10 CFR 50, APPENPIR B, CRITERION Ix, STATE, IN PART, THAff S
f ACCOMPLISHED...USING QUnLIFIED PROCEDURE...IN ACCORDA CE WITH APPLICADLE CODES, STANDARDS, SPECIFICATIONS, CRITERIA, AND UTHER N
SPECIAL REuulREMENTS." PARAGRAPH 17.1.9 0F THD QUALTTY ASt,UR ANCE PROGRAM DOCUMENTED IN APPROVED PS AR DEVI A!!DN Nt). 24-NP STATES, IN PART, THAT:
- THE WPPSS QA PROG AM REQUIRES., DEVELOPMENT AND INPLEMENTATION OF MEASURES FOR THE CONTROL UF !PECIAL R
(
PROCESSES...SUCH PROCESSES AS... WELDING..." AND THAT "... EQUIPMENT UTILIZED IN THE PERFORMANCE.. 0F SPECIAL> PROCESSES THAT SHALL BE QUALIFIED TO ITS INTENDED USAGE PRIO.TO BEING USED..." THE ASME BOILER AND PRESSURE VESSEL CODE R
REQUIPE QUALIr! CATION SECTIONS III ANp IX PROVIDE REQUIRE M NTS FOR QUALIFYING WELDING PROCEDURES FOR USE ON ASME SECTION III, CLASS'2, WELDED f
CONNECTIONS. THE PETEP KIEMIT SONS CO. (CONTRACT 3240-251) WELDING DROECDURE FOR JOINING SAFETY INJECTION SYSTEM 40" PENETRATION A 93E 93 LIES NO. 23 AND 2'l (WELp3 NUMBER 5) IS PROCl]URE PMS-WPS-eS. 4HE JOINTS INVOLVE +THE WELDING OF A P-1, GROUP 1, MAJERIAL 70 A P-1, GRDUP 2, NOTCH TOUGHNE SS TESTED M ATERI AL4 AS SHOWN ON EDASCO DRAWING NO. 3240-G-1300, " REACTOR SUILDING PIPING f
PENETRATIONSe* THIS 13 AN ASME SECTION III, CLASS 2 NELD.
CONTRARY TO THE nEQUIRENENTS, ON MAY 29, 1981, WELDING PROCEDURE PMS-4PS-gS hap OEEN SPECIFIED FOR USE DN WELDING P[NETRATION ASSEHnL1ES NOS. 23 AND 24 AND HAD BEEN USED UN UNIT 3 ASSEMBLY NO.
24,
- ELD No. 5, MITHOUT PROPER QUALIFICATION. THEiPROCEDURD WAS NOT. QUALIFIED FOR THE,TWO DIFFERENT BASE METAL GROUPS INVOLVED C
IN THE WELD 3 NO HAXIMUM INTERPASS TEMPERATURD WAS SPECIF2ED IN THE WELDING PROCEDUREf AND THE PROCEDURE' ALLUMED WELDING.
AMPERAGES IN EXCESS OF THAT QUALIFIED (I.E. PKS-MPS-RS ALLONS WELDING 0F t/8 INCH [7018 FILLER MATERIAL'AT EMPERAGES UP TO 200 AMPSe WHEPEAS THE PROCEDURE WAS QUAL 1F1ED, BY P3R'S NOS. 3 AND Me WITH AMPER AGES OF' 125 AMPS AND 180 AMPS),
88f1 06-03-81 06-26-81 CLEAF INSPECTION ROUTINEt(
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00CRET/ REPORT INSP/D ATE S FINDINGS EX CODE SEV TYPE' N008 O
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05-20-80 05-23-80 CLEAR INSPECTION ROUTINE' (
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8006 06-25-80 07-18-80 NONCOMPLIANCEt INSPECTION ROUTINE: (
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10 CFR 50, APPENPik R.
CRITERION MIV, STATESe IN PART, THAT " MEASURES SHALL BEtESTABLISHED TO INDICATE...THE! STATUS Of INSPECTIONS AND TESIS PERFORMED UPON INDIVIDUAL' ITEMS OFI THEi NUCLE AR P0MER PLANT....THESE' MEASURES SHALL PROVIDF. FOR THE.
O IDENTIFICATION OF ITEM 9 dalCH HAVE SATISFACTORILY PASSED RECUIRED INSPE;CTIONS AND TESTSe NHERE NECESSARY, TU PRECLUDE INADVERTENT eVPASSING OF SUCH INSPECTIONS AND TESTS,,.."
PARAGRAPH 17.1.14 0FtTHE QA PRUGRAM SIATES, IN PARTI THAT "...THE.
WPPSS OUALITY ASSURANCE PROGRAM REQUIRES THAT CONTRACTOR'S INSPECTION, IEST AND OPERATING STATUS PROCEDURES ARE MRITTEN AND O
SUBMITTEP FUP I?EVIEd ANfi COMMENT BY THElAE'.
THES
E. PROCEDURE
S SHALL ESTABLISH HEASURES WHICH PRUv!DE FUH
"...B)
THE 3'
IDENTIFICATIUN OF ITEMS dHICH HAVE PASSED REQUIRED INSPECTIONS AND TESTS, WHERE;NECESSARY, TU PRECLUDE INADVERTENT B PASSING OF*
SUCH INSPECTIONS AND TESTS...."
CONTRARY TO THE?REQUIREMENIS, AS OF8 JULY 9, 1986 THE' CIVIL / STRUCTURAL CUNTRACTOR WURMING UNDER O
CONTRACT SPECIFTCATION 3290-263 FOR STRUCTURAL STEELtERECTION AT UNITS 3 AND 5 HAD NOT ESTABLISHED MEASURES MHICH IDENTIFY ITEMS O
THAT HAVE SATISFACTORILY PASSED REQUIRED INSPECTIONS AND TESTS SUCH THAT INSPECTIONS AND TESTS ARE.NOI INADVERTENTLY BfPASSED.
THE INSPECTION OF THE BOLTED JOINT CONNECTING STRUCTURAL: BEAM NO. 2TBC TI THEtUNIT 1 AUr1LIARY BUILD!NG NEST MALL: AT THE 362.5 AS RErnRTED AS INSPECTED AND ACCEPTED RY THE CONTRAC ORES QC PERSONNEL ON JANUARY 4e 1980 DN IMEr STRUCTUR alt STEEL-O C
FT. ELEVATION W T
ERECTION CHECMLIST, WHEREAS IN JULY 1980 IT dAS FOUND THAT THE JOINT WAS IMPROPERLY ASSEMBLED AND THAI THE JOINT INSPECTION HAD BEEN INADVERTENTLY MYPASSED.
8007.
08-18-80 08-14-80 CLEAR INSPECTION =ROUTINEf(
=
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800R OR-09-80 08-28-80 CLEAR INSP[CTION ROUTINE'(
O O
8009 08-29-80 09-26-80 NONCOMPLIANCEt INSPECTION ROUTINEl(
EDA 3
A 250073C-STAT S IN Pt.RT THAT " MEASURES SHALL BE ESTARLISHED TO ASSURE Thai APPLICAHLE REGULATURY to CFR Sue APPENDIX Be CRITERION IV, E
1 O
REGHIREMEHTSe DESIGN BASE 8e AND OTHgit REQUIRENENTS WHICH ARE,NECESSARY 10 ASSURE' ADEQUATE QUALITY ARE SUITABLY INCLUDED OR Q
REFERENCED IN DUCUMENTS FOR PROCUREMENT OF MATERIAL, EQllIPMENT, AND SERVICES...."
PARAGRAPH 17.1.4 0F THE QA PROGRAM AS SPECIFIED IN THE PSAR STATES INPART THAT a...fHE.WPPSS QA PROGRAM pEnUIRES THE!REVIEH AND APPROVAL OF MPPSS AND Ett4SCO GENERATED
! O PROCUREMENT DOCUMENTS. TNESE REVIEWS VERIFY THE: INCLUSTUN OF APPLICARLE-TECHNICAL ~AND QUALITY REQUIREMENTS....a TARLEI3.2-1 UFr Q
THE PSAR SPECIFIES THAT THE EMERGENCY DIESEL GENERATORS AND THE BORIC. ACID MAMEUP PUMPS ARE QUALITY CLASS I.
CONTRARY TO THE l
REQUIPEMENTSe AS OF SEPTEHRER 15, 1980 CONTRACT SPECIFICATION NO. 324-251 (ENTITLED " ERECTION OF PIPING SYSIEMS AND INSTALLATION ti O OF MECHANICAL EQUIPMENT =),
A WPPSS/EBASCO GENERATED PROCUREMENT 00C0MENie IDENTIFIED THE EMCRGENCY DIESEL GENERATORS AS QUALITY Q
CLASS II, a3 Or SEPTEMAER 22, 1980, T'IE S AMEl CONTR ACT SPECIFIC ATInN IDENTIFIED THE' BORIC ACID MAKEUP PUMPS AS QU ALITY CLASS II.
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', f DOCKET / REPORT INSP/ DATES FINnINGS EX CODE SEV TYPE' HOD 8 O
O 05000509 8080 09-23-80 09-26-80 NONCOMPLIANCEt INSPECTION ROUTINE'(
EEC 2
A 2927068 O
j 10 CFR 50, APPENDIX R.
CRITFRION V, STATES IN PARTE THAT " ACTIVITIES AFFECTING QUAltTY SHALL BE PRESCHIBED BY DOCUMEh(ED' INSTRUCT 10NS* PROCEDURE 9, OR DRAWINGSe OF A TYPE. APPROPRIATE'TO THE CIRCUNSTANCES.... INSTRUCTIONS, PROCEDURES, OR DRAWINGS SHALL'
- O INCLUPE APPPOPRIATE QltANTITATIVE OR QUALITATIVElACCEPTANCE. CRITERIA FOR DETERNINING THAT INPORTANT ACTIVITIES HAVE.BEEN SATISrACTORILY ACCOMPLI 3HED....=
PARAGRAPH 17.I.5 Or THE' QUALITY ASSURANCE PROGRAH DOCUMENTED IN THEiPSAR STATES, IN PART, THAT INCLUDING E6ASCO AND C-E, A EtREQUIRED TO HAVE'MRITTEN INSTRUCTIONS, PRUCEDURES. POLICIES AND/OR R
- CONTPACTOPS AHP VE WDR S, O
DRAWINGS Mit[CH GOVERN THEIR QUALITY RELATED ACTIVITIES AND WHICH INCLUDE APPROPRIATE QUANTITATIVE AND QUALITATIVE' O
ACCEPTANCE / REJECTION CRITERIA...."
CONTRACT SPECIFICATION NO. 3240-251, ENTITLED " ERECTION OF PIPING SYSTEMS AND INSTALLATION OF MECHANICAL EQugPMENT,. APPLICABLEiTO SITE NORK OY THEiPETER KIEwi SONS' COMPANY, STATES, IN PART IN PAHAGRAPH 2.8 THATe O
- RECEIVING, HANPLING AND STORAGE OF All' MATERI ALS SHALL' COMPLY HITp ANSI N45.2.2-1972.
LEVELS OF' STORAGE SHALL-BE. DESIGNATED BY O
THE ENGINEER...."
APPENDIX 2.A-D TO THE' SPEC 1FICATION INCLUDES A (HART IN PARAGRAPH 2.2 WHEREIN THE ENGINEER DESIGNATED ANSI N45.2.2 LEVEL 8 AS THE STORAGE LEVEL' FOR THEiCHARGING PUMPS, SECTION 6,1.2 0F' ANSI N45.2,2-19 72 DEFINES STORAGE REQUIREMENTS O
FOR LEVEL 0 EQUIPHENT TO INCLUDE STORAGE IN AN AREA THAT IS "NELL D AINED."
CONTRARY TO THE REQUIREMENTS, 09 SEPTEMBER 23, O
R 19M0, THE PETER MIEWIT SONS' COMPANY PROCEDURE NO. PKS-WI AI01, ENTITLED '"AREiAND HAINTENANCE INSPECTION FOR CHARGING PUMPS,*
THE GOVERNING PPOCEDURE CONCERNING INPLACE. STORAGE.Or THE' CHARGING PUMPS, DIO NOT INCLUDE THE APPROPf11 ATE ACCEPTANCE CRITERI A O
FOR A WELL DRAINED STDRAGE' AREA.
FURTHER, THE FINALtSTORAGE LOCATIONS FOR UNIT 5 CHARGING PUMPS NOS. 05-CH-PP-003, 004 AND 005 3
AND UNIT 1 CHARGING Pl.tMP NO. 03-CH-PP-004 WERE NOT WELL DRAINED IN THAT THE: FLOOR DRAINS WERE PLUGGED SHUT AND THE: FLOORS OF.
THESE AREAS WERE COVEPED WITH MATER TO A DEPTH OF ONE: INCH DURING THEiPERIOD SEPTEHBER 23-26, 1980.
8011 10-09-60 10-09-80 CLEAR INSPECTION-SPECIALt 3
0 g
fO MUl2 30-21-10 10-24-80 CLEAR INSPECTION ROUTINE' (
=
=
Soli 09-29 10-30-80 NONCOMPLIANCEI INSPECTION ROUTINEt(
ECA 4
A 248063C' to CFR 50, APPENDIX 8, CRITERION III, STATES, IN PART, THATe "ME ASURE4 $H ALL' BE! ES T ABLISHED TO ASSURE TH A T APPLICABLE REGULATORY G
REQUIREMENTS AHp THE: p ESIGN DASIS...ARE CORRECTLY IRANSLATED INTO.'..DRAMINGS..."
PARAGRAPH 17.1.3 0F fME QUALITY ASSURANCE G'
PROGRAM DPCUNENTED IN THEiPSAR STATES, IN PART, THAT, " PRIOR TO SUSNITTAL Or DESIGN DOCUMENTS TO EITHER WPPSS OR ESASCO FOR REVIE" AN/0P APPROVAL, THE DESIGN CONTRACTOR $,
INCLUDING EBASCO, ARE RESPONSIBLE FOR VERIFYING THAT THE DESIGN MEETS T HE' G
REQOgPEMEttTS OF THE SPECIFICATIONS..."
CONTRACT SPECIFICATION NO. 3240-95 (ENTITLED, " STRUCTURAL STEEL PHASE I") SPECIFIES THAT Q.
THE DESIGff FOR STRUCTHR AL' STEEL SH ALL DE IN ACCORDANCE WITH PROJECT SPECIFICATION NO. 3240-448 (ENilTLED " STRUCTURAL STfEL"),
SPECIFICATION HO. 3240-118, PARAGRAPH 2.6 STATES, IN PART, THAT, " FIELD CONNECTIONS SHALL BE FRICTION TYPE JUINTS.,." AND THAT O
CONNECTIDHS SHALL BE IN ACCORDANCE WITH SPECIFICATION NO. 3240-50twa (ENTITLED "HIGH STRENGIH BULTED FIELD CONNECTIONS FOR Q
STRL'CTURAL STEEL").
SPECIFICATION NO. 3240-50lWA, PARAGRAPH 6 STATES, IN PART, THAT, " JOINTS SHALL tiF'FNICTION TYPE BULTED CONNECTIONS DETAILED FOR AN ALL0dABLE dORKING STRESS IN SHEAR OF 15,000 PSI..."
CONTRART TO THE REQUI.EMENTS ON SEPTEMBER 29, O
1960, THE STEEL FABRICATOR'S DESIGN DRAWINGS FOR STRUCTURAL STEEL REAM CONNECTIONS, DETAILED JOINT CONFIGURATIONS WHICH EXCEEDED Q
THE 15,000 PSI BOLT STRESS LIMIT OF SPECIFICATION 50lwA (FOUGHT DRAWINGS NC.-
40, 41, 44, 48, 49, 206, 207, 248, 304, 341, 343, AND 350) AND SPECIFIED THE USE OF GEARING TVPE JOINTS, WITH ACCOMPANVING SHE,..I $ TRESSES OF 29,200 Tu.31,900 PSI (FOUGHT DRANING O
HOS. 40, 41, AND 44).
FURTHERMORE, THEIINSTALLING CONTRACTOR'S QUALITY PROGRAH DID NOT ADDRESS THE INSPECTIION OF BEARING TYPF Q
t',
J0! HTS (1.E.,.N0 nOLT THREADS IN THEiSHEAR PLANES).
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09/25/81 XPPSS INSPECT. HISTORY-JAN 00 TO PRESENT PAGE'24
'O 00CRET/REPDPT INSP/ DATES FTNDINGS EX CODE SLV TYPE MODN O
I O
05000509 8u13 09-29-80 10-30-80 NONCOMPLIANCLI INSPECTION ROUTINE' (
EEB 5
A 248063C' O
to CFR 50, APPENDIX H, CRITERION V STATES, IN PART, THAT, " ACTIVITIES AFFECTING QUALITY SHALL BE PRESCRIBED BY DOCUMENTED INSTRUCTtDNS..AND SHALL BE IN ACCORDANCE WITH THESD INSTRUCTIONS..e PARAGRAPH 17.4.5 0Fi THE: JU ALI T Y ASSURANCE' PROGRAM DOCUMENTED O
IN THE PSAR STATES, IN PART, THAY, " PROVISIONS ARE MADEsFOR ASSURING.THAT ALL QUALITY RELATED ACTIVITIES ON STRUCTUNES,.,ARE Q
PERFORMED IN ACCORDANCE d!TH APPROVED INSTRUCTI3NS..,'
CONTRACT SPECIFICATIONS NOS, 3240-263, 3240-448, AND 3240-50ln4 SPECIFY THAT STRUCTURAL STEEL ROLTING SHALL REIINSTALLED IN ACCORDANCE WITH INSTPUCTIONS IN THE'AISC SPCIFICAllON FOR STRUCTURAliJOINTS O
U9fNG ASTM A325 OR A490 80LTS-19T2 (HIGH STRENGTH BOLTS). THIS INSTpUCTION REQUIRE 8 THAT BOLTING BE flGHTENED. CONTRARY TO INE O
REQUIPEMENTS, ON UCT0nER 22, 1980, THE' HIGH STRENGTH BOLTS WERE LOOSE' IN THE STRUCTURALiJOIkTS JOINING REAMS 295 B TO 293 8 AND 219 F/292 E TO 39 A AT THE 362.5 FU3T ELEVATInN IN THE UNIT 5 REACTOR AUXILIARY BUILDING.
IHESE JOINIS HAD BEEN INSPECTED AND O
ACCEPTED ON JULY 19, 1980 AND SEPTEMBER 10e 1980 O
O 8014 09-25-80 10-30-80 NONCOMPLIANCD OTHER
, -INVESTIGA EMA 6
A 2927058 10 CFR 50, APPEwrIX 0, CRITERION XII STATES, IN PART, "ME ASURES SHALU BE' EST ABLISHtD TO ASSURE THAT TUOLS, GAUGES, INSTRUMENTS, ANG OTHER MEASHRING AN9 TESTING DEVICES AREi... PROPERLY...CAllRRATED...AT SPECIFIC PERIODS..."
PARAGRAPH 17 4.12,3,A 0FITHE O
WASHINGTON PUBLIC POWER SUPPLY SYSTEM QUALITY ASSURANCEtPROGRAM DOCUMENIED IN THD PS AR ST ATL3, IN PARie IHAT,'*... SITE CONTRACTORS' APPROVED PROCEDURES ESTABLISH A SYSTFH FOR THE. CONTROL, CALIBRATION AND ACJUSTMENT OF TOOLS, GAUGE 8e INSTRUMENTS ANDDTHER INSPECTION, MEASURING, TESTING AND MAINTENANCD DEVICES USED AT THE' SITE'.
THIS SYSTEN IS ESTABLISHED SUCH THAT O
CONFORMANCE TO ESTABLISHED REQUIREMENTS IS VERIFIED AT SPECIFIC PERIDOS OF TIME'TO ASSURE THE USAGE 30F PROPER TYPE, RANGEiAND PROCEDURE NO. OC -S-10, REVISION 2, OF THEt SITE HVAC' CONTR ACTOR, MALLACE/ SUPERIOR, STATES, IN PART, P
ACCURACY Pr THE DEVICE.*
"ALL CALIRRATION RECORDS SHALL BEiR NIENED AT THE BEGINNING OF.EACH MONTH BY THF PROJECT QUALITY ASSURANCE MANAGER / DESIGNEE.,."
E O
CONTRAFY 10 THE REQUIREMENTS ON SEPTEMBER 25e 1980, THEt WALLACE/ SUPERIOR CALIBRATION RECORDS HAD NOT GEEN REVIEWED BY THE PROJECT QUALITY ASSURANCp MANAGER OR DESIGNEE SINCD JULY 1, 1980 FURTHERMOREe THD C AL.75 RATION RECORDS FOR FIVE PIECES OF EQUIPHENT HAD NOT REEN PECALLED AND RECALTBRATED WITHIN THD DA ES SPECIFIED ON THEiCALIBRATION RECORD.
T 8085 1t-18-80 11-21-80 NONCOMPLIANCEt INSPCCTION ROUTINEi(
EEA 2
A 2480618 O
to CFR 50 APPENDIX R, CRITERION V, AS IMPLEMENTED BY SECTION 17.9.5 0F'THE QUALITY ASSURANCE PROGRAM bJCUMENTED IN THE APPROVED.
O PSAR DEVIATION to-wP, STATES, IN PART, THAT "#CTIVITIES AFFECTING gUALITY SHALL RE PRESCRIBED BY DOCUMENTFD INSTRUCTIONS, PROCEDURES, OR PRA41NGS OF A TYPE-APPROPRI ATE TO THE' CIRCUMST ANCEq AND SHALL BE. ACCOMPLISHED IN ACCORDANCE WITH THESE-O INSTRUCTIONS, PROCEDURES, OR pRAWINGS."
CONTRACT SPECIF1 CATION NO. 3240-265e ' REACTOR BUILDING CONCRt.IE CONSTRUCTION", THE GOVERH1NG SPECIFICATION FOR THE CONTRACTOR'S (J. A. JONES CONSTRUCTION COMPANY) NORK ACTIVIIIES ON THE REACTOR BUILDING, STATES
- CONTRACTOR SH LL SUDMIT THE' ORIGINAL COMPLF1ED NONCONFORM ANCEI REPORT WITH IN PARAGRAPH 14.6.9 THAT FOR NONCONFORMANCD REP 3RTS, A
O APPLICABLE SUPPORTING ENGINEERING AND INSPECTION DOCUMENTATION TO ENGINEER'S QUAllTY ASSURANCE SITE' SUPERVISUR." PARAGRAPH 14,6.6 STATES THAT, "FOR NHS REVIEWED NONCONFORMANCES, ENGINEER SHALL' ALSU WIINESS THE* RE-INSPECTION, DETERMINE'IT8 ACCEPTABILITY AND SIGN OFF THE NONCONFORMA CEIREPORT AFTER PRIOR CONTRACTOR INSPECTION AND APPROVAL.*
CONTRARY TO THE N
O, REQUIREMENTS, THE J. A.
JONES CONSTRUCTION COMPANY PROCEDURES AND RELATED WORK PRACTICES DID NOT INCORPORATE fHC SPECIFTCATION REQUIREMENTS OF NOTIFICATION TO AND WITNESSING 3r REINSPECTIONS DY THEiENGINEER. THIS PROCEDURE NAS APPROVED FOR USE BY THE COHTRACIOR ANf3 THE ENGINEER.
8016 10-31-T0 s2-04-80 CLEAR INSPECTION ROUTINE: (
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- EXCLUDES 2.790 INFORMATION DOCNET/ REPORT INSP/ DATES FTHDINGS EN CODE SEY
- TYPE, H00s 0
05000509 Soli 12-08-80 12-19-80 NONCOMPLIANCEI INSPECTION ROUTINEl(
EJA 2
A 292706C-O 10 CFR 50, APPENPIE H, CRITERION IX, STATES, IN PART, THAT, " MEASURES SHALL*BEiESTABLISHED TO ASSURE THAT SPECIAL PROCESES, INCLUDING WELDING,...ARE CONTROLLED AND ACC0"PLISHED BY QUALIFIED PERSONNEL USING QUALIFIED PROCEDURES IN ACCORD ANCE: WITH APPLICABLE CODES..."
PARAGRAPH 17.4.9 0F THEi Q'JALITY ASSURANCE PROGR AM DOCUMENTED IN THE PSAR STATES, IN PART, THAT O
... PERSONNEL PERFORMING SPECI AL PR3 CESSES AT TNE' CONSTRUCTION SITE WILL BE-QUALIFIED AS REQUIRED BY THE APPLICABLE CODEIAND STANDARDS..."
CONSTRUCTION CONTRACT NO. 3240-232 SPECIFIES THAT THEL AwS D1.1 STRUCTUR AL WELDING CODE IS THE APPLIC ABLEI CODE FOR
~
C STRUCTURAL WELDING, INCLUDING QUALIFICATION. FIGUREi5.27 0FiTHE AWS CODE IDENTIFIES THE CONFIGURATION OF THE' GUIDED-BEND TEST O
JIG TO BE USED IN TESTING WELDER QUALIFICATION TEST CDUPONS.
THE FIGURE -SPCIFTES THAT FOR HATERIAL*NITH A YIELD STRENGTH OF LESS THAN 50,000 P3I THE PLUNGER AN3 INTERIOR DIE RADII SHAll. BE 3/4 AND l-3/16", RESPECTIVELY. CONTRARY TO THE. REQUIREMENTS, ON O
DECEMBER 16, 1980. IT dAS FOUND THAT THE SITEIHVAC CONTRACT OR (CONTRACT 3240-232) HAS BEEN QUALIFYING WELDERS USINC AN O
HO HA E!BEEN MAKING QUALIFICATION TEST COUPONS WITH ASTM A-36 MATERIAL (VIELD INP P0l'E RLY SIZED Cu!DED-5END TEST JIG. WELDERS W V
STRE9GTH OF APPPnXIMATELY 36,000 PSI) NAVEtBEEN QUALIFIED BASED ON TESTING WITH A JIG HAVING PLUNGER AND INTERIOR DIE RADII 0F' O
l' AND l-7/16*, PESPECTIVELY.
G C
8101 01-13-81 C1-16-81 NONCOMPLIANCEI INSPECTIONdOUTINEl(
EE8 5
A 2927068 10 CFR 5@, APPENDIX 8, CRITERION V,
AS IMPLEMENTED 8Y SECTION 17.4.5 Dr'THE QUALITY ASSURANCE PROGRAM DOCUMENTED IN IHE APPROVED PSAR DEVIATION 88-NP, STATES, IN PART, THAT
- ACTIVITIES AFFECTING QUALITY...SHAtts BEi ACCOMPLISHED IN ACCURD ANCE R w!NGS."
HDRRISDN-KNUDSEN ADMINISTRATIVE' INSTRUCTION PROCEDURE. NUMBER 15, " STUD HELDING G
f MITH.. INSTRUCTION PROCEDURE OR D A
INSPECTION PPOCEDUREe" ST ATES IN PAR AGRAPH 6.3 TH AT, *E ACH OPER ATOR SH ALL BEND THE: FIRST TWO STUDS ON EACH DAT'S PROD 9CTION 10 id DEGRCES AND THE FIRST Two STUDS ON EACH HENBER TO 30 DEGREES," IN PARAGRAPH 6.8 THAT, "THE 00ERATON SHALL* CIRCLE WITH A PAINT C
STICK, OR PAINT A LINE UP THE SHAN< OFeTHEiFIPST TWO STUDS BENT ON EACH NEW 4 EMBER," AND IN PARAGRAPH 6.5 THAT, "ALL FERRULES MUST DE DPOKEN OFF RY THElOPERATOR PRIOR TO INSPECTION.* CONTRARY TO THE REQUIREMENTS, ON JANUART 14, 1981, ON THE SOUTHSIDE OF-UNIT 5 ELEVATION 362'e THE INSPECTORS ORSE VED THE: FULLONING (1) A STUD PELDING OPER\\ TOR NELDING ON A MEMBER BETWEEN COLUMNS R
C NOS CA-12 ann CA-13 HAD WELDED APPR0rINATELY SIXTY STUDS WITHOUT BENDING THE FIRST TMO STUDS, (2) A NUMBER OF STUDS NERE FOUND MHICH dERE BENT DUT HA0 NOT RECEIVED THE NECESSARy PAINT NARM.
17 WAS LATER DISCOVERED THAT THE GUALITY CONTROL INSPECTOR HAD BEEN MARKING THE STUDS, NOT THE' OPERATOR. THIS SECOND ITEM HAD BEEN OCCURRING FOR AN INDETERHINATE TIME IN BOTH UNITS 3 AND 5.
C (3) NUMERDHS STUPS dEPE FOUND WITH PARTS OF THEiFERRULES STILL IN PLACE.
THESE SIUDS HAD BEEN INSPECIED AND ACCEPTED BY THE HORRISON-MNUDSEN QUALITY CONTROL INSPECTOR.
6102 01-05-81 01-30-81 NgNC0HPLIANCEf INSPECTION ROUTINEt(
EEA 2
4 248063C' 10 CFP 50, APPEND 11 B, CRITERION Ve STATESe IN PART THAT,
- ACTIVITIES AFFECTING QUALITY SHALL BE*FRESCRIBED BY DOCUMENTED INSTRU T!DNS, PROCEDURES, OR DRAdINGS, OF A TYPE APPROPRI ATE TO THE CIRCUMST ANCES AND SHALL' BE ACCOMPLISHED IN ACCORD ANCE' WITH g
C C
THESE INSTRUCTIONS, PROCEDURES, OR DRAWINGS.*
PARAGgAPd 17.l.5 0F THE MPPSS QA PROGRAM, AS DOCUMENIED IN THE PSAR, STATES, IN INSTRUCTI NS, PPOCEDURES, POLICIES, AND/OR DRAWINGS MHICH GOVERN THEIR
=...gnNTR AC ORS... ARE REQUIRED TO H AVE sot!T I;N O
PART THAT, T
Q GUALITT-RELATED ACTIVITIES AND WHICH INCLUDE APPROPRImTE! OUANTITATIVE AND QUALITATIVE ACCEPTANCE / REJECTION CRITERIA....*
g APHS 3.8.5.6 A D 3.8.3.6 0F THE dPPSS PSAR SPErIFIES THAT CONSTRUCTION NILL BE-PERFORMED IN ACCURDANCE MITH THE AMERICAN PARAGR N
NATIONAL STANDARD ANSI N15.2.5.
THEtAMERICAN HATIONAL STANDARD ANSI N45.2.5, PARAGRAPH 5.4, STATES, IN PART THAT, "... A LLi G
CONNECTION POINTS SHALL BE VISUALLY INSFECTED FOR THE FOLLOWING I TE at s: 1 BOLTS ARE THE CURRECT LENGTH... CORRECT TYPEI BOLT IS g
USED...dASHEPS ARE USED dHEN REQUIRED....*
CONTRACT 3240-263 FOR JTRUCTURAL STEElsERECTION REQUIRES lHAT BOLIING BEiPERFORNED IN ACCORDANCE MITH THE AMERICAN NATIONAL' STANDARD ANSI N45.2.5.
C01TRARY TO THE REQUIREMENTS, fME 3240-263 CONTRACTOR'S
,6 APPROVED PROCEDUPE, WHICH HAD REEN IMPLEMENTED PRIOR TO JANUARY 21, 1981, REQUIRED INSPECTION Of DNLY 203 OR TWO 80LTS PER g
l CONHECTIUM POINT.
THIS PROCEDURE 13 INAPPROPRIATE IN THAT IT PRESCRIRES INSPECTION RE"flREMENTS LESS THAN THOSE.SPECIF'IED IN THE CONTRACT SPECIFICATIONS AHD ANSI N15.2.5.
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..t' DOCKET / REPORT INSP/ DATES FINDINGS EX CODE SEV TYPEI' HOD 8 Q
INSPECTION ROUTINET(
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A 248063C 9
(
05000509 Siv2 01-05-81 01-30-81 NONCOMPLIANCEI.
"A PROGRAM FOR INSPECTION OF ACTIVITIE8 SHALL' BE EST ABLISHED AND 10 CFP 50, APPENDIX R, CRITERION X, STATES, IN PART THAT, l
EXECUTED...TO VERIFY CONFORMANCE WITH THE DOCUNENTED INSTRUCTIONS,, PROCEDURES, AND DRAWINGS FOR ACCOMf'LISHING THE ACTIVITY...."
O PARAGRAPH 17.81.10.3 0F TNE MPPSS QA PROGRAM AS 3DCUNENTED IN THE PSAR, STATESe IN PART THAT,
- SPECIFIC CONTRACTOR INSPECTIONS 9
VERIFYING CONFORMA CE' T3 CONTR ACT REQUIREMENTS... AND ACCEPT ABILITY OF H ATERI AL AND EQUIPMENT WHICH HAVE N
ARE TO RE PEPFORMED FOR BEEN INSTALLED AND ERECTED ON THE CONSTRUCTION SITE'ARE'IN ACCORDANCE.WITH APPROVED SITE' CONTRACTOR PROCEDURE 8,..."
APPROVED
,O SITE CONTPACTOR (3240-263) PROCEDUREi 40. CP-35 REQUIRES THAT BOLTING BE: PERFORMED IN ACCORDANCE WITH APPROVED ERECTION ORANINGS Q
A Ni) T'H A T PLATE OR BAR-TYPE WASHERS BE USED O'8 TNE' OUTER PLY OF JOINTS HAVING LONG SLOTTED HULE6,. ERECTION DRAWING NO. G-34.15 DESIGNATES THAT WASHERS SHALL BE'USED FOR ANCHOR BOLTING COLUMNS. CONTRARY TO THE. REQUIREMENTS, ON JANUARY 21, 1981, SDLTS' O
CONNECTING UNIT 3 BEAMS 235E AND 23fD TO THE' WALL CL1P dERE NOT EQUIPPED WITH PLATE OR BAR WASHERS UVER THE LONG SLOTTED HOLES O
UNIT 3 COLUMN HO. 12A HAD BEEN ANCHOR BOLTED WITHOUT ThE USE.OF WASNERSg AND UNIT 5 CONNECTION OF BEAN 43C TO COLUMN 419A CONTAINED UNE BOLT dtTHOUT THE REQUIRED WASHER. CONTRACTOR QUALITY RECORDS INDICATED THAT THIS BOLTING HAD BEEN PREVIOUSLY O
IHSPECTED AND ACCEPTED BY THE CONTRACTOR'S QUALITY CONTROLtSTAFF.
9 0
8192 D1-05-81 01-3d-81 NONCOMPLIANCEI INSPECTION ROUTINEl(
ET9 3
A 248063C' 10 CFP 59, APPENDIX B, CRITERION XVII, STATES, IN PART THAfe = SUFFICIENT RECORDS SHALL BE MAIN 7AINED TO FURNISH EVIDENCE; UF:
ACTIVITIES AFFECTING QUALITY...tNSP CTION AND TEST RECORDS SHALL, AS A HINIMUN, IDENTIFY THE INSPECTOR OR DATA RECORDER....'
E O
PARAGRAPH 8.7 UF CONTRACT 3240-263, PROCEDURE' N3. CP-05 lENTITLED, " STRUCTURAL' STEEL' ERECTION"), REQUIRES THE' DEVELOPMENT OF' CTUR L' STEEL
- CONNECTIONS AND REQUIRES THAT EACH CONNECTION SHALL BE VERIFIED AS COMPLETE BY
- AS-BUILT" DFAdING RECURDS FOR STRU A
SIGNIFYgNG WITH (QC) INITIAL DR STAMP FOR THAT CONNECTION. FURTHER, THE'PROCEDUREiREQUIRES THEt DOCUMENT ATION UF BOLTING-O INSPECT 10NS OR INSPECTIO'd REPORT FORM NO. QC-19 FIR.
THIS FORM INCLUDCS AN AREA TO IDENTIFY THE SPECIFIC ITEMS INSPECTED.
COHTRARy TO THE RE0IREMENTS, ON JANUARY 21, 1991, THE FOLLONjNG RECORD DISCREPANCIES WERE IDENTIFIED: (1) THEiCOMPLEfTED AS-DUILT DRAMING FOR UNIT 5 STRUCTURALISTEEL ASSOCIATED WITIl CONCPETE* PLACEMENT NO. SABS-010-362 CONTAINED ND VERIFY 1NGeINITIALS
(
OR INSPECTION STAMPS.
(2)
QC-19 FIR NO. 5-SR-42 DATED NOVEMBER 6, 1980 INDICATED EfGHT BOLT 3 NERE INSPECTED IN EACH OFIFOUR CONNECTIONG (Two Nua'HERED 270F-260 A AND TWO NUMSERED 270F-262A) WHE, {N FACT, THE' DESIGN DRAWINGS AND ACTUALtINSTALLATION N
CONTAINEP ONLY FOUR BOLTS PER CONNECTION. $1HILARLY, CONNECTION N(). 251F-247Eh263C MAS REPORTED TO HAVE 14 BOLTS WHEN DNLY 12 MERE REQUIRED AND INSTALLED. (3) A Qg-IgFIR FORM COULD NOT BE LOCATED FOR THE INSPECTION OF BOLTING ON UNIT 3, COLUMN NO. 12Ap
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ALTHOUGH, CONTPACTOR PEPRESENT ATIVES REPORTED T'ilS BOLTING' COMPLETE AND ACCEPTED IN MARCH 1980 C-S 8103 02-25-81 02-25-81 CLEAR INSPECTION HANAGEMEN
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2370558 to CFP 50, APPENDIX 8, CRITERION VI, STATES, IN parit "ME ASURES SHALL' BE: EST ABLISHED TO CONTROL. THE ISSUANCEt 0Fi DOCUMENTS, SUCH
- O AS INSTRUCTIONS, PROCEDURES, AND DRAWINGS, INCLUDING CHANGES THERETO, WHICH PRESCRIBE ALL. ACTIVITIES AFFECTING QUALITY.
THESE.
O MEASUPES SHALL ASSURE THAT DOCUMENTS, INCLUDING CHANGES...ARE' DISTRIBUTED TO AND USED AT THE LOCATION WHERE THE PRESCRIBED ACTIVITY IS PERFORMED..."
PARAGRAPH 17.2.6 0F THE, QUALITY ASSURANCE: PROGRAM STATES, IN PARTt
"...APPR.1VED CHANGES ARElPROMPTLY O
INCLUDED WHEPE APPLICABLEiINTO INSTRUC.TIONS, PROCEDURES, DRAWINGS, AND OTHER APPROPRIATE DOEUHF,NTS.. 0830LETE OR SUPERSEDED O
INAD ERTENT USE'..." CONTRARY TO THE REQUIREMENTS, AS OFiAPRIL*16, 1981, THEiEBASCO SITE 4 DOCUMENTS APE CONTROLLED 10 PREVENT V
SUPPORT ENGINEERING (ESSE) GROUP HAD NOT ESTABLISHED HEASURES TO ASSURE THAT APPROVED CHANGES TU DoctJMENTS AREe DISTRIOUTED AND
> C USED.
SEVEN DRAWINGS WERE IDENTIFIED IN ESSEtCONTROLLED FILE *NO. R-15 WHICH DID NOT INCLUDE APPROVED CHANGES THAT APPL'IED TO O
TIIESE' DRAWINGS (WPPSS/EnASCO DRAWINGS 3240-G-2520-Stp 2520-S2: 2521 2539 2550p 1300-43 AN D 1325),
I 8108 04-33-81 04-23-81 NONCOMPLIANCEI INSPECTION ROUTINE' (
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A 2480348 WHICH GOVERNS STRUCTU AllSTEEL BFAH FABRICATION, SHC93 THAT STIFFEv a PLATES ARE COPED OR R
ERASCO DRAnING NO. 3240-G-3357, O
CLIPPED AT THE BEAM WEB AND FLANGE INTERSECTIONS AND THAT FILLET WELDS TERMINATE AT sHE COPED EOGE'UF THE STIFFENER PLATE.
l CONTRARY TO THE REQUIREMENT, ON APRIL 20, 1981, MOST OFITHE STIFFFNER PLATE WELDS ON STRUCTURAL BEAMS NOS. Ol19D, D35A, D63A, D640, Ft88, F69F, FilB, A250, 318A, 3088, AT A SITEtETORAGE A"EA, DID NOT TERMINATE.AT THE COPED EUGE OF THE STIFFENER PLATES, O
BUT CONTINilED THPOUGH THEtCOPED AREAS.
THESE' H AD BEEN PREVIOUSLY INSPECTED AT THE FABRICATION SHOPS AND ACCEPTED.
0 880R 04-I3-81 04-23-81 NDNCOMPLIANCEI INSPECTION ROUTINEl(
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PARAGR PH 5.02, SPECIFYING filUALITY RELATED REQUIREMENTS FOR PLACING (FORMED CONC E E.CONSTRU TION),
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SPECIFICATION NO. 3240-112, A
AND FIELD nENDING REINFORCING STEEL, STAT S, IN PART:
"...REBAR SHAT.L DE COLD BENT USING PROPER BAR BENDING. EQUIPMENT AND THE' E
C DIAMETER OF THE BEND HEASURED ON THEL INSIDE' 0F THE BAR SH ALL6 NOT BE LESS THAN THEiFOLLOWING...t BAR SIZE, NOS. 3 THRU 8, NOS.
3 9,
10, 13 MINI!NM DIAMETERS, 6 BAR DIA*ETERS, 8 BAR DIAMETERS..., RESPECIIVELY" CONTRARY TO THE8E GOVERNING. INSTRUCTIONS, ON APRIL 22, 1981, THE REINFORCING BAR RENDING EQUIPMENT, UTILIZED BY MORRISON-RNUDSEN.FOR FIELD BENDING OF SAFETY-RELATED C-REINFORCING STEEle HAD BENDING PIN SIZES WHICH RESULTED IN A DEND iNSIDE DIAMETER SHALLER THAN THOSE REQUIRED BY THE 3
SPECIFICATION, FOR BAR SIZES 4, 5, 6e P,
10, AND 11 BY ABOUT t.3 BAR DIAMETERS FOR NO. 4 BARp 2,24 dAR DIAMETERS FOR NO. 5 BARg 1.9 RAR DIAMETERS FOR NO. 6 PAR 1.25 BAR DIANETERS FOR NO. O BAR 3 BAR DIAME.TERS FOR NO, 10 BARF AND 3 BAR DIAMETERS FOR Q-v NO. Il DAR.
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ADMINISTRAftVE SITE PPOCEDURE ASP-C1-4-ty, REVISION 0 (ENTITLED ' CARE!AND ISSUE OF MEASURING AND TESTING EQUIPHENT"), IN EFFECT j
FROM MARCH 20, 1980, TO MARCH 3, 1981, AND PROJECT SITE' PROCEDURE PSP-MM-ll-9, REVISION 0 (INTERIM) (ENIITLED ' CARE AND ISSUE OF O
MEASURING AND TEST EQUIPMENT *),
IN EFFECT SINCE MARCH 3, 1981 PROVIDE DETAIL INSTRUCTIONS ON THE' CARE, HANDLING, AND ISSUANCE Q
0F CALIBRATED EQUIPMENT USED TO PERFORM QUALITY CHECKS. BOTH Or THESr 'ROCEDURES STATE, IN PART,
"...AT NU TIME IS HEASURING g
g AND TEST EQUIPMENT (0 BE ISSUED WHEN ANY DAMAGElIS SUSPECTED..." C01ThARY TO THE REQUIREMENTS, CALIBRATED TORQUE. WRENCH (SE RI Ali fQ NO. 33741) MAS RETURNrD TO THE C ALIBR ATION STDRAGE' AREA ON DECEMBER 22, 1980, WITH A WRITTEN ST A TEHt NT INDICATING II WAS Q
DAMAGED, PEQUIRING REFAIR. ON *tARCH 6, 1981, THE WRENCH HAD NOT BEEN PEPAIRED BUT MAS ISSUED FOR USE' AND WAS USED TO CHECM THE' TORQUE OF 00LTS ON A REACTOR COOLANT PUMP MOTOR SUPPORT, AS DF APRIL'16, 1981. THEtWRENCH TURQUE GAUGE STILL HAD A BROMEN GLASS
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10 CFR 50, APPENPIR M,
CRIsERION III, STATES, IN PART, THATI
- ME ASURES SH ALL BE! EST ABLISHED TO ASSURE THAT APPLICABLE O
REGL'LATORY PFOUTREMENTS AND THE DESIGN BASIS...ARE CORRECTLY TRANSLATED INTO... DRAWINGS...."
PARAGRAPH 17.1.1 0F THE. QUALITY O
ASSL'R ANCE P90GR AM DOCUMENTED IN APPROVED PSAR DEVIATION NO. 26-NP, STATES, IN PART, THAT: "... PRIOR 10 SUBMITT AL: (OF DESIGN DOCtWENT) TO EITHER dPPSS OR EDASCO FOR REVIEM AND/OR APPROVAL, THE SCSIGN CONTRACTORS, INCLUDING E8ASCO, AREl RESPONSISLE FOR O
VERIFYING THAT THE DESIGil MEETS THE REQUIREMENTS OF' THE' SPECIFIC ATION...."
THE PSAR, SECTION 3.2, PRUVIDES FOR SAFETY-RELATED O
ASME-PIPE SUPPORTS TO BE DESIGNED IN ACCORDANCO WITH THE ASME BOILER AND PRESSURE VESSEL CODE, SECTION III.
SECTION III, APPENDtX XVII, PARAGRAPH 2452.1, SPECIFIES THE NIN! HUN ALLOWABLE FILLET WELD SIZES FOR VARIOUS THICKNESSES OF WELDED CONNECTIONS O
UN PIPE SUPPURTS. CONTRARY TO THE; REQUIREMENTS, ON HAY 29, 1981, IT HAS DETERMINED THAT CONTRACTOR DESIGN DRAWINGS FOR ASME 3
S AFETY-RELATED PIPE StfPPORTS NOS. 3G-CH-135' (OND WELD)3 3G-CH-163 (Tw0 MELDS)r AND 3G-CH-267 (ONE: MELD) SPECIFIED MELDS SMALLER TilAN THE MINIMUM SIZE PERMITTED SY THElASMElCODEISECTION III APPENDIX XVII, PARAGRAPH 2452=1.
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,O THE HANDLING, STORAGE, SHIPPING, CLEANING AND PRESERVATION OF. MATERIAL AND EQUIPMENT 6..TD PREVENT DAMAGE OR DETERIORATION."
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PARAGfiAPH 6.1.2 0F PROCEDURE PDP-N-405d or THE J. A. JONES CONSTRUCTION COMPANY, A.SITEtCONTRACTOR RESPONS18LE FOR CONSIRUCTION ACTIVITIES INVOLVING SAFETY-RELATED PIPING AND COMPONENTS, ST ATES THAT FOR PIPING AND COMPONENTS = PROTECTIVE 6 COVERING, END CAPS lO AND OTHER PROTECTIVEiDEVICES WILL SEtUTILTZED AND MAINTAINED." FURTHER, PARAGRAPH 6.3 0F J. A. JONES'PROCEDURL JAJ-wl-005, O
3 REVISION 2E, STATES THAT, " SPACE HE ATERS FOR EQ'JIPMENT SET IN PLACE SHALL SE' ENERGIZED WITHIN TM0 DAYS AFTER EQUIPMENT IS INSTALLED.* CONTRARY TO THESE REQUIRENENTS, ON APRIL 29, 1980t (3) AT THE 399 FOOT ELEVATION UFiTHE UNIT 4 GENERAL SERVICES D
SUILDING SPACE HEATERS WERE NOT ENERGIZED IN THE' S AFETY-RELATED Elt;CTRIC MOTORS OF: THREE. M AKE-UP SYSTEM PUMP IJNITS, T W Oi O
CONTAINMENT SPRAY PUNP UNITS AND Th3 DECAY HEAT REMOVAL' PUMP UNITS.
(2) THE FLANGES OF UNIT 4 MAKEkUP SYSTEM PUMP HUS>PMP>lA, A SAFETY-RELATD COMPONENT, WERE EN ANS N O PROTECTIVE' COVERING OR PROTECTIVE C APS NERE. INST ALLED..
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10 CFR 50, APPENDIX B, CRITERION V, AS IMPLEMENTED BY SECTION 17.1'5 0F THE QUAL.ITY ASSURANCE PROGRAM DOCUMENTED IN THEt PSAR AND THE WPPSS QA PP0 GRAM MANUAL PROCEDURE CAP-2, PARAGRAPH 3.1, STAIES, IN PART, THAT *ACTIYtTIES AFFECTING QUALITY SHALL BE' O
PRESCRIDED DY DOCUMENTED INSTRUCTIONS, PROCEDURES OR DRAWINGS, OF A TYPE APPROPRIATE TO THE CIRCUMSTANCES AND SHALL.BE 3
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CONTRARY TO THE REQUINEMENTS, PRIUR TO JUNE, 1980, UNIVERSITV NUCLEAR SYSTEM, I N C t, (UNSI) Ih!TIATED THE'USE OF A FORM TITLED " QUALITY CONTROL problem REPORT" TO IDENTIFY
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NONCUHFORMANCES, DEFICIENCIES AND PROBLEMS WITH ACTIVITIES AFFECTING THE QUALITY OF' CONSTRUCTION OF. SAFETY-RELATED HEATING, VENTILAftnN AND AIR CONDITIONING (HVAC) SYSTEMS IN UNIT NOS. I AND 4 CONTAINHENTS AND GENERAL SERVICES BUILDINGS, THE.USE OF THIS FORM WAS NEITHER DESCRIBED IN THElAPPROVED QUAL 17Y ASSURANCE PROGRAM NOR WAS IT CONT 70LLED BY A DOCUMENTED INSTRUCTION OR O
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THIS PROCEDUPC AND THE REFERENCED CODES AND STANDARDS," CONTRARY TO THE REQUIREMENTS, PRIOR TO JANUART 28, 1981, UNSI GENERALLT DID 10T DOCUMENT WELOS WHICH HAD BEEN REPAIRED.
6102 01-26-81 01-30-81 NONCOMPLIANCEt
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,O CONTRAPY TO THE REQUIREMENTS OF 10 CFR 50, APPENDIX 8, CRITERION 5, AS I:tPLEMENTED SY THE.WPPSS 04 PROGHAM AND PSAR AND UNSI PROCEDURE NCP/CP 10.0, A NONCONFORgANCE REPORT HAD NOT BEEN ISSUEQ TO DOCUMENT A SAFETY-RELATED NONCONFORMING CONDITION DETECTED RY OMEC (uNSI 01 SITE) DURING SITE' CONSTRUCTION ACTIVITIES. ON DECEMBER if, 1980, UNSI IDENTIFIED, IN QUALITY CONTROL O
PROBLEM REPOPT NO. 172, THAT 24 dELDMENTS 4AD BEEN INSTALLED IN THE UNIT 4 GENERAL SERy!rES BUILDING (GSB) UN QUALITY CLASS I i
HANGERS (NUS. 20, 28, 22 AND 23 01 DRAi4 NG NO. DS-4590, SHEET 7) USING STRAIGHT POLARITY. THE APPROVED MELDING PROCEDURE I
SPECIFICATIONS FOR THE WELDMENTS 3PECIF1ED THE USE OF REVERSE 1 POLARITY.
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JUN 171963 Docket No. 50-397 EA-80-20 Washington Public Power Supply System ATTN:
Mr. N. O. Strand Managing Director P. O. Box 968 Richland, Washington 99352 Gentlemen:
The apparent iter:s of noncompliance listed in Appendix A to this letter were identified during our investigation of construction activities at the Washington Nuclear Project No. 2 and at your contractor's shops in Seattle, Washington.
This investigation was conducted between November 27, 1979 and February 28, 1980.
Several items of noncompliance described in Appendix A concern the sacrificial shield wall and pipe whip restri.ints and clearly show that significant problems existed in your quality program during the fabrication of these structures at your contractor's Seattle shop during the period 1976-1978.
Furthermore, recent reinspections of these structures revealed defects which require major repairs and analyses before the structures can be declared acceptable for service.
Notably, the sacrificial shield wall was constructed and certified
(
correct by your contractor although the upper and lower sections of this structure were not properly welded together.
Consequently, the structure as built is incapable of withstanding the shear forces postulated during accident conditions.
The failure to detect such deficiencies until this late date represents failures of not only the contractor's quality program but also those of the Architect Engineer / Construction Manager and the Washington Public Power Supply System.
Compounding these conditions is that significant deficiencies in the shield wall were identified to you in November 1978.
As of October 1979, these had not been adequately investigated nor an effective corrective action program developed.
Moreover, in the Management Meetings of May 18, 1978 and June 6, 1978, we expres-sed our concern with the effectiveness of your quality assurance program to con-trol contractor activities for areas other than those contained in Appendix A.
These same concerns were reiterated during a meeting with you on April 24, 1979.
The enclosed items of noncompliance raise a question concerning the adequacy of your control of the quality assurance program in accordance with criteria I, II, XVII, and XVIII of Appendix B,10 CFR 50, and paragraphs D.1, D.2.5, and 0.2.7 of your quality assurance program described in the PSAR.
Consequently, in addition to the civil penalties described below I have issued the accompanying 50.54(f) letter to seek additional information about the quality of the work at your facility before making a determination whether or not to take further action.
/'
CERTIFIED MAIL h
x RETURN RECEIPT REQUESTED _
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JUN 17 EED Washington Public Power Supply e System As you are aware from the " Criteria for Determining Enforcement Action," which was provided to you by letter dated December 31, 1974, the enforcement actions available to the Commission in the exercise of its regulatory responsibilities include administrative actions in the form of written notices of violation, civil monetary penalties and orders pertaining to the modification, suspersion or revocation of a license.
After careful evaluation of the items of noncompliance identified in Appendix A and other results of our investigation conducted between November 27, 1979 and February 28, 1980, this office croposes to impose civil penalties, pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, (42 USC 2282) and 10 CFR 2.205, in the cumulative amount of
$61,000 as set forth in the " Notice of Proposed Imposition of Civil Penal-ties," enclosed herewith as Appendix B.
This letter also reaffirms our Immeliate Action Letter of November 21, 1979, which specifies that no repairs or attachments shall be made to the sacrificial shield wall until the correc-tive action plan has been reviewed by the NRC staff.
You are required to respond to this letter within twenty-five days, and in preparing your response you should follow the instructions contained in Appendices A and B.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the Nuclear Regulatory Commission's Public Document Room.
Sincerely, Victor Stello, Jr.
Director Office of Inspection and Enforcement
Enclosures:
1.
Appendix A, Notice of Violation 2.
Appendix B, Notice of Proposed Imposition of Civil Penalties cc w/
Enclosures:
~
M. E. Witherspoon, Division Manager
/
Quality Assurance, WPPSS
~
W. C. Bibb, Manager, WNP2 Project, WPPSS Glenn C. Walsley President, Board of Directors Route 5, Box 5010 Pasco, Washington 993001
.SEE PREVIOUS YELLOW FOR CONCURRENCES 4
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System or revocation of a license.
After careful evaluation of the items of noncompliance identified in Appendix A and other results of our invest,igation conducted between November 27, 1979 and February 28, 1980, this office proposes to impose civil penalties, pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, (42 USC 2282) and 10 CFR 2.205, in the cumulative amount of
$49,000.00 as set forth in the " Notice of Proposed Imposition of Civil Penal-ties," enclosed herewith as Appendix B.
This letter also reaffirms our Immediate Action Letter of November 21, 1979, which specifies that no repairs or attachments shall be made to the sacrificial shield wall until the correc-tive action plan has been reviewed by the NRC staff.
Yoe are required to respond to this letter within twenty-five days, and in preparing your response you should follow the instructions contained in Appendices A and B.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the Nuclear Regulatory Commission's Public Document Room.
Sincerely,
{
Victor Stello, Jr.
Director Office of Inspection and Enforcement
Enclosures:
1.
Appendix A, Notice of Violation 2.
Appendix B, Notice of Proposed Imposition of Civil Penalties cc w/
Enclosures:
M. E. Witherspoon, Division Manager Quality Assurance, WPPSS W. C. Bibb, Manager, WNP2 Project, WPPSS Glenn C. Walkley President, Board of Directors Route 5, Box 5010 Pasco, Washington 993001 Q.
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APPENDIX A NOTICE OF VIOLATION Docket No. 50-397 Construction Permit No.: CPPR-93 EA-80-20 Based on the results of NRC investigation conducted between November 27,1979 and February 28, 1980, it appears that certain of your. activities were not conducted in full compliance with conditions of your NRC Facility License No.
CPPR-93.
The NRC investigation revealed significant deficiencies in your quality assurance program, in that work performed by contractors and subcontractors did not conform to the criteria of 10 CFR Part 50, Appendix B, as described in Appendix D of your PSAR.
Specifically, as of November, 1979, the items listed below had not been identified nor corrected.
I.
Items of Noncompliance Relating 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 accomplished in accordance with these instructions, procedures, or drawing's.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance k
criteria for determining that important activities have been satisfactorily accomplished."
Paragraph D.2.5.5 of the QA Program states in part, that " Activities affecting quality... shall be accomplished in accordance with these instructions, procedures, or drawings...."
The erection of the reactor building sacrificial shield wall is prescribed, in part, by drawing No. 2808-5836, Revision 2, Note NN, 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 still in place at the interface of the bottom segment ring beam and the top of the box ring beam.
These shims prevented several slot welds from joining the ring beams.
This Violation resulted in' the as built structure being incapable of performing its intended safety function during design basis earth-quake conditions and certain postulated pipe break accidents (Civil Penalty - $5000.00).
pp/Afhk
Appendix A
- B.
10 CFR 50, Appendix B, Criterion XI states "A test program shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures...."
Paragraph 2.5.11 of the QA Program states in part, " Test procedures shall include provisions for assuring that prerequisites for the given tests have been met... "
1.
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, entitiled
" Technical Documentation and Procedure Requirements" states, in part, that "... Document (including test procedures) is to be submitted for 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 was performed before an owner-approved procedure was provided.
Comoonent Weld Joint Date Ring beam 1138 Joints 23, 24 June 17, 1976
(
113C Joints 31,32 114C Joints 23, 24 Box Column 29B Joints 21-28 June 16, 1976 29A Joints 1-8 Weld Maps W45 Joints 9-10 July 24, 1976 W21 Joints 1-6, 8-10, 12, 13 W22 Joints 1-4, 6-3, 10, 11 12, 13, 167 W22 Joints 15, 16, 22, 132, 140 30, 168, 144, 32, 33, 35, 37, 166 Electro-Slag X-100 June 2, 1976 X-102 The contractor's 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 nonconforming condition was not identified nor were the weld joints retested after an approved procedure was provided.
This is an Infraction (Civil Penalty - $3000.00).
o
Appendix A -
2.
The fabrication, erection, rnd testing of the sacrificial shield wall is prescribed in part by WPPSS Contract Specifica-tion No.
2808-215 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).
SNT-TC-1A specifies that individuals who read and interpret indications (test results) shall be certified NOT Level II or III and that the certification is not transferable between employers.
For certification, as a NDT Level II, an individual must be administered a general written examination (covering basic test principles); 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 examina-tion 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:
An individual, who was never qualified by the contractor, a.
k-performed nondestructive ultrasonie testing on the sacrificial shield wall plates Nos. b56 and f56 on June 2, 1976.
b.
An individual performed ultrasonic testing (UT) on the sacrificial shield wall ring beam 113b, welds 23/24 on June 17, 1976; ring beam 1146, welds 15/16 on June 17, 1976; subassemble 56b for segment 22A, welds 212 to 235 on June 17, 1976; box column 296, welds 21 to 28 on June 16, 1976; ring 3 dwg 56, welds 100 and 102 on June 2, 1976; ring 8, pc 252c, weld 115 on August 4, 1977, and others without having taken a practical examination'which was in accordance with SNT-TC-1A.
Specifically, no check points were defined or applied to the examination as required by SNT-TC-1A, and the examination document did not demonstrate that an individual certified as a NDT l
Level III conducted or graded the examination.
This is an Infraction (Civil Penalty - $3000.00).
l C.
10 CFR 50, Appendix B, Criterion IX, states that dMeasures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Appendix A -
Paragraph 2.5.9 of the QA Program states:
" Measures shall be established an'd documented by the contractor to assure that special process, including welding, heat treating, cleaning, and nondestruc-tive examination, are accomplished under controlled conditions in accordance with applicable codes, standards, specifications, criteria and other special requirements, using qualified personnel and proce-dures.
Documentation shall be maintained for currently qualified personnel, processes, or equipment in accordance with the requirements of pertinent codes and standards.
For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined."
The fabrication of the sacrificial shield wall is prescribed in part, by WPPSS Contract Specification No. 2808-215.
This document specifies that welding shall be in accordance with the AWS Structural Welding Code D.1.1-1974.
1.
Paragraph 3.7.2.4 of the Structural Welding Code states, in part, that for the repair of cracks in welds or base metal,
"... Ascertain 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 completion signatures dispositioning " Incomplete / Rejection Tags" Nos. 5257, 5325, 5412, 6055, 6056, 6058, 6059, 5443, 5444, 5445, 5446, and 5447 demonstrate that the repairs made to cracks in shield wall subassemblies during the period of April 1976 to April 1977 were made without using acid etching, magnetic particle testing, or other positive means 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).
2.
Paragraph 3.4.3 of the Structural Welding Code states, in part, 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 comment to the engineer.... "
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
Appendix A 1 document, entitled, Sact ificial Shield Wall Assembly Procedure" which was an informal document, not signed or controlled by the contractor.
This is an Infiaction (Civil Penalty - $3000.00).
3.
The Structural Welding Code.
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 application 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, procedures, or drawings were provided to control the application of localized 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. 00094, 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 the actual tcmperatures reached during this activity.
Temperature control during the
-(-
heat straightening process is important in assuring retention of the as built physical properties of the material.
This is an Infraction (Civil Penalty - $3000.00).
D.
10 CFR 50, Appendix B, Criterion XVII, states that " Sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following:
operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.
The records shall also include closely related data such as qualifica-tions of personnel, proceo'ures, and equipment.
Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location and assigned responsibility. "
l Paragraph D.3.4.17 of the QA Program 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, monitoring of work performance...
10
Appendix A -
Inspection and test records will, as a minimum identify the inspector or data recorder, the type of observation, the results, the accepta-bility, and the action taken in connectior, with any deficiencies noted.
Required records will be identifiable and retrievable..."
Contrary to the above requirements:
1.
On January 24, 1980, quality records were not retrievable which identify the individuals who performed meny of the visual inspections on the shir.1d wall, as indicated by the following examples:
Shield wall manufacturing orders for pieces a15,15c, d15, a.
gR14, ti13,14V and b17 (no serial numbers had been recorded on these manufacturing orders) documented inspec-tions performed 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.
b.
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 identity of this individual.
Shield wall Manufacturing Orders 2000, 2002, 2020, 1866 c.
(
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 permit verification that the inspections were performed by qualified personnel.
This is an Infraction.
(Civil Penalty $3,000.00) 2.
On January 23, 1980, information contained in quality records was inconsistent and did not accurately reflect activities performed on the shield wall as indicated by the following examples:
Shield wall ultrasonic test report for piece No.113/78 is a.
not dated and results of testing are not indicated, b.
Shield wall Manufacturing Order No. 000917 indicates that welds 1-4 on drawing 75 were performed using welding procedure No. 0001-13-06 (the electroslag welding process);
the weld map for these welds indicates the welds were made using procedure No. 0001-01-10 (the shielded metal arc welding process).
O l'
~
Aopendix A -
Two shield wall weld maps Nos. W256 exist.
One map c.
indicates welding electrode serial Nos. A333ER/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 omissions and inconsistencies resulted in records which do not provide assurance that these activities were satisfactorily performed.
This is an Infraction (Civil Penalty - 53000.00).
II.
Items of Noncompliance Relating to Pipe Whip Restraints A.
10 CFR 50, Criterion IX states: Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, stanaards, specifications, c.riteria, and other special requirements.
10 CFR 50, Criterion XI states:
A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performeo in accordance with written test procedures T..
which incorporate the requirements and acceptance limits contained in applicable design documents.
The test program shall include, as appropriate, proof tests prior to installation, preoperational tests, and operational tests during nuclear power plant or fuel reprocessing plant operation, of structures, systems, and components.
Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions.
Test results shall be documented and evaluated to assure that test requirements have been satisfied.
Paragraph D.2.5.9 of the QA Program states:
Measures shall be established and documented by the contractor to assure that special processes, including welding, heat treating, cleaning, and nonde-l structive examination, are accomplished under controlled conditions in accordance with applicable codes, standards, specifications, criteria and other special requirements, using qualified personnel and procedures.
Documentation shall be maintained for currently qualified personnel, processes, or equipment in accordance with the requirements of pertinent codes and standards.
For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall M defined.
m i
l l
l l
Appendix A '
Paragraph D.2.5.11 of the QA Program states:
A test program shall be established to assure that all testing required to demonstrate that the item will perform satisfactorily in service is identified and documented, and that the testing is performed in accordance with written test procedures which iricorporate or reference the require-ments, nd acceptance limits contained in applicable design documents.
The tesa program shall cover all required tests, including as appro-priate, prototype qualification tests, proof tests prior to installa-tion, preoperational tests, and operational tests to verify continued sa.tisfactory performance during operation.
Test requirements and acceptance criteria shall be provided by the organization responsible for the design of the item under test, unless otherwise designated.
Test procedures shall include provisions for assuring that prerequisites for the given test have been met, that adequate instru-mentation is available and used, and that necessary monitoring is l
performed.
Prerequisites include such items as calibrated instrumen-tation, appropriate equipment, trained personnel, condition of test equipment and the item to be tested, suitable environmental conditions, and provisions for data acquisition.
Test results shall be documented and evaluated to assure that test requirements have been satisfied.
1.
The fabrication of safety related pipe whip restraints is prescribed in part by WPPSS Contract Specification No. 2808-90.
{(
Division 5, Section 5A, " Technical Specifications for Pipe Whip 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 owner."
Contrary to the above requirements, ultrasonic testing was performed on pipe whip restraints Nos. PWS 30-5, PWS 27-17, and PWS 6-1 in September and October 1976 before owner-approved procedures were provided.
Contractor procedures for this work (QCP 8.0, Revision 0, " Nondestructive Testing Procedure for Ultrasonic Inspection;" QCP 8.2, Revision 0, " Qualification and Certification 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 nonconforming condition was not identified nor were the weld joints retested after an approved procedure was provided.
This is an Infraction (Civil Penalty - $3000.00).
2.
The testing of safety related pipe whip restraints is prescribed in part by Contractor Procedure No. QCP 8.0, Revision 0, "Nonde-structive Testing Procedure for Ultrasonic Inspection." Paragraph 4.4 of this Procedure, states, in part, that "... Before the angle beam examination, the area of the base material through
Appendix A
-g-which sound will travel in angle beam examination shall be completely scanned with a straight beam search unit to dete:t any reflectors which might affect the interpretation of angic beam results... "
Contrary to the above requirements, the ultrasonic test records for safety-related pipe whip restraints Nos. PWS 315-5, 315-6, 315-7, and 315-8, dated June 21, 1978, indicate that only angle beam examination 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).
SNT-TC-1A specifies that individuals who read and interpret indications (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 administered a general written examination (covering
(
basic test principles); a specific written examination (covering equipment, operating procedures, and techniques); and a practical examination (to demonstrate operation of equipment and analysis of resultant information).
Contrary to the above requirements:
An individual, who was never qualified by the contractor, a.
performed the required nondestructive 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, August 17, 1976, August 19, 1976, August 19, 1976, and August 25, 1976 respectively, b.
An individual, who had not taken a " specific" written ex, amination for magnetic particle testing as required by SNT-TC-1A, performed the required magnetic particle testing on pipe whip restraints PWS. 36-8 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).
Appendix A 4.
WPPSS Contract Specification No. 2808-90 for safety related pipe whip restraints specifies that work shall be done in accordance with the AWS Structural Welding Code 0.1.1-1974.
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 application 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, procedures, or drawings were provided to control the application of localized heat during the straightening of pipe whip restraints subassemblies as documented on Manufacturing Order Nos. 0710, 0726, 0730, 0735 and 0736 during August and September 1976.
Control of the maximum temperatures of the heated areas was not assured nor is there documentation of the methods used to measure the temperatures or the actual temperatures reached during the activity.
Temperature control during the heat straightening process is impor. tant in assuring the as built physical properties of the material.
This is an Infraction (Civil Penalty - $3000.00).
B.
10 CFR 50, Appendix B, Criterion XVII, states that " Sufficient
(
records shall be maintained to furnish evidence of activities affecting quality.
the records shall include at least the following:
operating logs and to.: results of reviews, inspections, tests audits, monitoring 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 observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility."
Paragraph D.3.4.17 of the QA Program states in part, that " Sufficient l
records will be prepared as work is performed to furnish documentary l
evidence of the quality of items and of activities affecting quality
... The Records include, as a minimum, the results of reviews, inspections, tests, audits, monitoring of work performance...
Inspection and test records will, as a minimum, identify the inspector or data recorder, the type of observation, the results, the accepta-bility, and the action taken in connection with any deficiencies noted.
Required records will be identifiable and retrievable...
i i
I.
I
w
~
Appendix A '
Contrary to the above requirements:
1.
On January 24, 1980, quality records were not retrievable which identify the individuals who performed mcny of the visual inspections on pipe whip restraints as indicated by the following examples:
Pipe whip restraint Manufacturing Order No. 0457 for PWS a.
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.
b.
Manufacturing Orders 0213 and 0686 for restraints PWS 53-1 and 54-14 document inspections performed by an inspector No. 9 on July 21-22, 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 the inspections were performed by qualified personnel.
This is an Infraction.
(Civil Penalty - $3,000.00) 2.
On January 23, 1980, information contained in quality records was inconsistent and did not accurately reflect activities
,y performed on safety related pipe whip restraints as indicated T.
by the following examples:
Magnetic particle test reports for PWS 36-23, 52-8, 36-1, a.
35-58, 34-58, and 32-7 contain data and inspection results written by one inspector and bear the photocopied signa-ture of a different inspector (the two individuals reported that they did not collaborate on the inspections involved).
b.
Ultrasonic test reports for restraints Nos. PWS 1-1 and 2-1 reported that the ultrasonic testing was performed 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.
This is an Infraction.
(Civil Penalty - $3,000.00) 3.
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.
This is an Infraction.
(Civil Penalty - $3,000.00)
~
Appendix A 4.
Magnetic particle inspection report for restraint PWS 35-9 reports that the testing was performed on welds 6 and 7 on August 4,1976; however, the record bears the photocopied signature of an inspector who was not hired until August 16, 1976.
This is an Infraction.
(Civil Penalty - $3,000.00).
III. Items of Noncompliance Relating to Recent Construction Activities 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 accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Paragraph D.2.5.5 of the QA Program 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 control of welding filler material, an activity affecting quality, 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 "..
Portable rod ovens shall be connected to a reliable electric source during the shift.
The pink copy of the Form NF-69 must remain with the rod until the rod is consumed or restocked... "
Contrary to the above requirements:
a.
On February 25, 1980 in reactor building room 3C at elevation 548, the subject contractor had a portable rod l
oven containing Type E7018 low hydrogen weld rod which was-open and not connected to a power source.
The weld rod i
was at ambient temperature, and the welder was not in the area.
i b.
On January 16, 1980, two unused coated electrodes and one partial length coated electrode were lying 1cose, unattended and not contained in a portable oven at eleva-tion 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.
l l
l r
Appendix A 4 c.
On January 17, 1980, six unused Type 7018 coated electrodes were similarly lying loose at elevation 560 in the reactor containment building.
The filler metal withdrawal Form NF-69 was not in the vicinity of the electrodes.
This is an Infraction.
(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 instructions delineated in Quality Control Procedure Number 24 Revision 8 (entitled " Hanger Inspection-Traceable Systems",
QCP-24) and Project Directive No. 75, Revision 4, (entitled
" Hanger Engineering Standards", PD-75).
Paragraph 10.2(A) of QCP-24 states, in part, " Visually inspect all welds... Weld size less than shown on as-built hanger is unacceptable..."
Paragraph 7.5 of PD-75 states, in part, that "The configuration of supports shall be in accordance with the as-huilt hanger detail...
" Paragraph 10.1.2 reiterates that " Unacceptable conditions are weld size less than shown on as-built.
Contrary to the above requirements, on February 26, 1980, safety related pipe hanger No. HPCS-48 had received quality control inspection by the subject contractor and was considered acceptable, yet the hanger had one fillet weld that was 1/16 inch undersize, 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 documenting inspections for safety-related pipe supports are prescribed in part by the prime site piping contractor's instructions delineated in Project Directive No. 75, Revision 4 (entitled " Hanger Engineering Standards", PD-75) and Quality Control Procedure Number 24, Revision 8 (entitled " Hanger Inspection-Traceable Systems", QCP-24).
Paragraph 5.3 of PD-75 states, in part, that " Engineering shall indicate the NDE...
and visual inspection required for traceable systems."
Table 1, page SA, of the same document specifies magnetic particle (MT) or liquid penetrant (PT) examination of ASME Section III, Class II, attachment welds to pressure parts.
Paragraph 10.2(A) of QCP-24 states, in part, " Visually inspect all welds... "
Further, paragraph 10.3 of QCP-24 states, in part, that "If the welds are acceptable... initial, stamp and date the applicable box on the NF-6A.
Assure that all NDE requirements and any A.I. ' Hold' point have been satisfied...."
e
Appendix A 14 -
Contrary to the above requirements, on February 26,1980, for-pipe support No. LPCS-12, engineering had not indicated the NDE and visual inspection requirements for lug weld number 6 on i
pipe support LPCS-12 nor had a quality centrol inspector initialed, stamped, or dated the applicable inspection box on the NF-6A form for this weld (other quality records, however, indicated that some NDE had been performed on the weld).
This is a Deficiency (Civil Penalty - $1000.00).
4.
The requirements for protecting safety-related instrument tubing are prescribed, in part, by the prime site alectrical contracter's Procedure CP208 which states under General Maintenance Requirements that, ".... covers, caps, plugs and other closures shall be maintained intact...." This procedure goes on to stata ".... dust coverings, shrouds, local sealing, heating methods and mechanical cleaning shall i
be employed to keep the structure as clean and dry as possible I
contrary to the above requirements, on February 28, 1980, safety related instrument rack No. H22-P005 had three sections of tubing which had been disconnected with the ends left open, exposing the internals of the system.
2 4~
This is an Infraction.
The failure to properly cover, cap, or plug safety-related instrument tubing was cited previously as an item of noncompliance in IE Inspection Report No. 50-397/
79-16.
(Civil Penalty - $4000.00).
This Notice of Violation is sent pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, code of Federal Regulations.
The Washington Public Power Supply System is hereby required to submit to this office within twenty days of the receipt of this Notice, a written statement i
or explanation in reply, including for each item of noncompliance: (1) admission l
or denial of the alleged item of noncompliance; (?) the reasons for the item of noncompliance, if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further items of noncompliance; and (5) the date when full compliance will be achieved.
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,4
APPENDIX B NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Washington Public Power Supply System Docket No. 50-397 EA-80-20 This Office proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as ametided (42 USC 2282), and to 10 CFR 2.205 in the cumulative amount of Sixty-one Thousand Dollars for the specific items of noncompliance set forth in Appendix A to the cover letter.
In proposing to impose civil penalties purs'. ant to this section of the Act and in fixing the proposed amount of the penalties, the factors identified in the Statements of Consideration published in the Federal Register with the rulemaking action which adopted 10 0FR 2.205 (36 FR 16894) August 26, 1971, and the " Criteria for Determining Enforcement Action," which was sent to the NRC licensees on December 31, 1974, have been taken 'into account.
The Washington Public Power Supply System may, within twenty-five days of the date of this Notice, pay the civil penalties in the cumulative amount of Sixty-one Thousand Dollars or may protest the imposition of the civil penalties in whole or in part by a written answer.
Should the Washington Public Power Supply System fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the amount proposed above.
Should the Washington Public Power Supply System elect to file an answer protesting the civil penalties, such answer may (a) deny the items of noncompliance listed in the Notice of Violation in whole or in part; (b) demonstrate extenua-ting circumstances; (c) show error in the Notice of Violation; or (d) show other reasons why the penalties should not be imposed.
In addition to protes-ting the civil penalties in whole or in part, such answer may request remission or mitigation of the penaltie::.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant tn 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
The Washington Public Powcr Supply System's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to answer and ensuing orders; answer, consideration by this office and ensuing orders; requests for hearings, hearings and ensuing orders; compromise; and collection.
Upon failure to pay any civil penalty due which has been subsequently determined in accoroance with the applicable provisions of 10 CFR 2.205, the,
matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended (42 USC 2282).
J
[
o JUN 171980 K
Docket No. 50-397 EA-80-20 Washington Public Power Supply System ATTN:
Mr. N. O. Strand Managing Director P. O. Box 968 Richland, Washington 99352 Gentlemen:
Subject:
10 CFR 50.54(f) Request Regarding Quality Assurance As discussed with members of WPPSS management during a meeting ;it your head-quarters office on May 30, 1980, and as detailed in the Notice of Violation which accompanies this letter, the NRC staff is concerned about the quality of construction at your Washington Nuclear Project No. 2 (WNP-2) site.
Specifi-cally, the IE staff does not at this time have sufficient information to conclude that WNP-2 has been constructed in substantial conformance with the construction permit.
Several items of noncompliance described in the Notice of Violation concern the sacrificial shield wall and pipe whip restraints and clearly show that significant problems existed in your quality program during the fabrication of these structures at the Seattle shop of your contractor, Leckenby Corp.,
during the period 1976-1978.
Furthermore, recent reinspections of these structures revealed defects which require major repairs and analyses before the structures can be declared acceptable for service.
Notably, the sacrifi-cial shield wall was constructed and certified correct by your contractor although the upper and lower sections of this structure were not properly welded together.
Consequently the structure as built may be incapable of withstanding the shear forces postulated during accident conditions.
The failure to detect such deficiencies until this late date represents failures of not only the contractor's quality program but also those of the Architect Engineer / Construction Manager, Burns and Roe, and the Washington Public Power Supply System.
Compounding these conditions is that significant deficiencies in the shield wall were identified to you in November 1978, and as of October 1979 these had not been adequately investigated nor an effective corrective action program developed.
Moreover, in the Management Meetings of May 18, and June 6,1978, Region V representatives expressed their concern with the effective-ness of your quality assurance program to control activities of your contractors or subcontractors, of whom there are approximately thirty at the WNP-2 facility.
These concerns were reiterated during a meeting with you on April 24, 1979.
By the end of 1978, in excess of twenty specific items of noncompliance had been identified at WNP-2 by the NRC.
During 1979 sixteen items were cited in addition to those covered in the accompanying Notice of Violation.
Further 49 0 fY 4f$
JUN ll D Washington Public Power Supply System
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review and analysis of these numerous items of noncompliance and related inspection findings indicate a common problem: ineffective control by WPPSS and Burns and Roe of the activities of contractors without NRC reviewed quality assurance programs.
In addition to Leckenby Corp., tt.c contractors or subcon-tractors demonstrating ineffective control include: (1) Wright, Schuchart, Harbor, Boecon, GERI; (2) Waldinger; (3) Seattle Industrial; (4) Industrial Heating and Plumbing; (5) Johnson Co.'trols; and (6) Fischbach-Lord.
The pattern and seriousness of noncompliances at WNP-2 are cause for our concern whether work in portions of the facility in addition to that worked by Leckenby Corporation has been properly accomplished and whether current and future work is being adequately controlled.
Therefore, urider the authority of Section 182 of the Atomic Energy Act of 1954, as amended, and Section 50.54 (f) of 10 CFR Part 50, information is requested on the steps which will be taken to provide reasonable assurance that your approved quality assurance program has been implemented such that structures, components, and systems, constructed by contractors not having an NRC reviewed quality assurance program are in accordance with conditions of your construction permit and those steps which will be taken to strengthen management control of the project.
Accordingly, submit within thirty days a plan and schedule for completion of review of completed safety-related work accomplished by those contractors not g
having an NRC reviewed quality assurance program to determine whether the L
quality assurance program was adequate to assure such work was properly performed.
De depth of review should be commensurate with the safety function of the structures, systems, or components and should include, but not necessarily be limited to, the following considerations:
Were there cases where the required quality procedures and a.
specifications were not applied to the work?
b.
Were there instances in which improperly qualified personnel performed and inspected the work?
Were receipt inspection requirements followed for contractor c.
produced items and why weren't deficiencies detected during receipt inspection?
d.
Were correct dispositions made for nonconformance reports, design changes, field change requests, and information requests?
On the basis of review of existing records and a sampling of pre-e.
viously inspected work, are quality and test records associated with the work complete and accurate?
The plan should include: (1) the rationale for selection of contractor item (s) for review, (2) provision for recorting results of the review to the NRC, (3) provision for reporting to the NRC repairs or further action to be taken for s
Y Washington Public Power Supply System those structures, systems, or components which are found to be deficient or questionable as a result of the review, and (4) provisions for evaluating the quality assurance programs at each of the WPPSS facilities based on lessons learned from the review.
You are required to respond to this letter under oath or affirmation.
In those cases in which a complete response must await the results of future activities, an interim reply shall be given within thirty days as well as the associated schedules for completion of the response.
3 l
We are continuing our investigations into quality assurance matters at your facility.
Your reply to this letter and implementation of corrective actions, as well as the results of our most recent investigations, will be considered in determining whether any further ehforcement action is required (such as suspension, modification or revocati6n of your license).
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the Nuclear Regulatory Commission's Public Document Room.
Sincerely, k
Victor Stello, Jr.
Director Office of Inspection and Enforcement
Enclosure:
i Notice of Violation Distribution:
V. Stello, IE R. C. DeYoung, IE R. H. Engelken, RV l
J. B. Henderson, IE J. M. Taylor, IE H. D. Thornburg, IE T. W. 8'rockett, IE G. W. Reinmuth, IE ELD g&Y IE Files Central Files hg
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=ImWby Washington Public Power Supply Syut.m I
A JCHNT cwt ATING AGENCY
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- N G T ON 99357 * ** ( ' e
- 09: 372 % CO Docket No. 50-397 t.
Muclear Regulatory Cocnission April 21, 1981 G02-81-82 Region V Suite 202, Walnut Creek Plaza
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1990 N. California Blvd.
Walnut Creek, California 94596 4
Attention:
P.r. R. H. Engelken. Director f$
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e
Subject:
WPPSS NUCLEAP. PROJECT NO. 2
__ e g DOCKET NO. 50-397, CPPR-53 jA.
A*
i POTENTIALLY REPORTABLE 10CFR50.55(e)
R CONDITION - WNP-2 NO. 144 - 215
+
s POSSIBLE INSTALLATION OF DEFECTIVE 4
R U
2" SCH. 80 PIPE u
Gentleen:
'pl In accordance with provisions of 10CFR50.55(e), your staff was inforned by telephone on March 9,1981 of the r,Jbject condition. The deficiency could, during an accident condition, result in degradation or loss in C
function of safety related systems in which the piping may have been r'
installed.
S. '".
L.i Attached is an interim report on the subject condition.
Please contac.
vs if you have additional questions.
E ~t b :.'
Very truly yours, j
l 9.v. f1ATLOCK i
Program Director, WNP-2
's RGM:HL8:dm attactnent (i
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AD Toth esident Inspector RE Snaith - Eurns & Roe P
h[7 JJ Verderber - Burns & Roe
' p-RC Root - Burns & Roe, site i
TA Mangels 1orf - Bechtel, site WS Chin - Bonneville Power Adr.in, rl(
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W. Wood - NRS Corporation f
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Interie Rerert i
P0TENTI ALLY RIPORTMLE 10CrR50.55(c) COCITION WPP55 hUCLEAR PROJECT NO. 2 1
POSSIBLE INSTALLATION OF DEFER.T!YE 2" SCH. 80 PIPE i
i WASHINGT0ft PUBLIC POWER SUPPLY SYSTEM DOCKET NO. 50-397 LICEMSE M0. CPPR-93 Potential Problem I
The potential problan involves the possible installation of 2" Sch. 80 piping, which may be defective, in Class I safety related systems. Failures of this piping during accident conditions could result in failure of the systems to perform their required functions.
The questionable piping may have been withdrawn from a quarantine area without performance of required inspections.
Approach to the Problen Quarantined and installed piping from piping heats identified as potentially defective will be subjected to detailed physical examinations to determine if deficient conditions actually exist.
Following the above detemination, any defective piping installed in Class I safety related system will be replaced. Stored piping will renain in quarantine untti deficient conditions are detemined.
Status of Proposed Resolution Piping of three different heats have been identified as questionable because of linear indications which exist.
Visual and liquid penetrant exa-inations have been made on piping from all of the heats, however, these examinations were not adequate to definitely establish that the piping is defective.
Plans for detailed examinations of piping sectioned from the different heats and for independent examinations of questionable installed piping have been established. The work to accomplish these examinations has not been started.
Reason Why a Final Report Will Be Delayed Additional time required to accomplish the required ex&minations and to establish the extent of rework required.
Projected Completion of Corrective Action and Report l
It is expected a final report identifying deficient conditions and corrective action can be provided ta the NRC by October 31, 1 9531.
____