ML20041E150
| ML20041E150 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 02/11/1982 |
| From: | Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20041E146 | List: |
| References | |
| GO1-82-0049, GO1-82-49, NUDOCS 8203100191 | |
| Download: ML20041E150 (5) | |
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[ Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 February 11, 1982 G01-82-0049 Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Attention: Mr. B. H. Faulkenberry Chief, Reactor Construction Projects Branch
Subject:
NUCLEAR PROJECT NOS. 1 & 4 NRC INSPECTION WNP-1 & 4 DATES OF INSPECTION DECEMBER 14--18, 1981 DOCKET N05. 50-460 AND 50-513 CONSTRUCTION PERMIT NOS. CPPR-134 AND 174 Ref.: 1) Letter from B. H. Faulkenberry to D. W. Mazur, NRC Inspection at WNP-1/4 Site, dated January 6, i982.
Reference 1) delineates the results of the December 1981, inspection of activities authorized by NRC Construction Permit Nos. CPPR-134 and
-174. Further, Reference 1) identifies an activity which was not conducted in full compliance with PSAR requirements as set forth in the Notice of Violation enclosed as Appendix A. This item of noncompliance deals with improper closecut of nonconformance reports, and has been categorized into a level as described in Supplement II of the Federal Register, dated October 7, 1980, (45FR66754) as the Interim Enforcement Policy.
The specific finding, as identified, and the Supply System's response is provided herewith as Appendix A.
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D. W. M-Program Director, WNP-14 DWM:MER:ns
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r3 5 cc: CR Bryant, BPA/399 .y ,__ ,g V Stello, Director of Inspection, NRC :: co gQ og A Toth, Resident NRC Inspector a .Cr 7
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8203100191 820303 PDR ADOCK 05000460 l
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Appendix A
- Washington Public Power Supply System -
Docket No. 50-460 P. O. Box 968 Construction Permit Richland, Washington 99352 No. CPPR-134 Finding A 10CFR50, Appendix B, Criterion V, and Section 17.1.5 of the PSAR state in part:
... activities affecting qualtiy shall be prescribed by documen-ted instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures, or drawings...."
Field Quality Standard, FQS 15-1, Revision 3, of May 2,1980, requires in paragraph III.B.l.d that, "All NCRs shall remain "open" until disposi-tion has been resolved, implemented, and reinspected and the NCR completed (closed)."
Contrary to the above, on December 11, 1980; January 7,1981; and February 3,1981, Nonconformance Report Nos.1-NCR-207-092, -090, and -087, respectively, were closed and signed off as having the disposition implemented and reinspected, whereas one of the required actions on each of these nonconformance reports of showing conditions on as-built
- drawings had not been accomplished or entered into a tracking system as an outstanding item.
i This is a severity Level V violation applicable to Unit I.
SUPPLY SYSTEM RFSPONSE Finding A Corrective Action Taken snd Results Achieved Supply System nonconformance report number, WNP-1/4-001, has been issued 4
to document the premature closeout 0, the subject Contract 207 NCRs.
The apparent cause of the deficiency is that in verifying the dispositions
- to Nonconformance Reports 1-NCR-207-092, -090, and -087, the as-builts would be provided as part of the normal execution of the contract which already required submittal of as-built drawings and, as such, reason for closing the NCR. The United Engineers & Constructors (UE8C) Contracts Administrator transmitted copies of the disposition NCRs to both Allied i Capital Steel (joint venture) and Shurtleff and Andrews to assure inclusion
] into the as-built drawings Action Taken to Preclude Recurrence An informational letter will be issued to UE&C &nd Bechtel Power Corpora-tion (BPC) by February 26, 1982, advising them that, in the event an a
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NCR or CNCR contains one or more elements, e.g., a combination of " Rework,"
" Repair," " Reject," or "Use-As-Is" in the disposition, it is the responsi-bility of the individual- verifying implementatin to assure that all the elements of the disposition have been satisfied. If for some reason, only a portion of the disposition can be verified, then an incremental buy off is necessary. In such cases, the portion accepted must be clearly identified on the nonconformance report and the nonconformance report will remain open until the remaining elements can be verified as being satisfactorily completed.
It is recognized that in dispositionir.g an NCR or CNCR "Use-As-Is" or " Repair," the actual as-built condition could deviate from the original design. To assure that the contractor's prepared as-built drawings reflect such changes, Bechtel will issue a letter of direction to affected site contractors requiring them to revise their as-built program to include incorporation of NCRs and CNCRs which have been dispositioned "Use-As-Is" or " Repair" and effect design. This letter will be issued by March 1, 1982, and will require the contractor to submit all necessary procedural revisions to Bechtel for approval by no later than April 1,1982.
The current UE&C program for processing of NCRs and CNCRs relative to as-b tilting, is described in FGCP-60, " Control Procedure for Drawings, Specifications and System Design Description," and FQS 15-1, " Control of Nonconforming Material Parts and Components." These procedures adequately delineate which nonconformance reports are to be incorporated into the design documents and how they are to be processed to ensure timely incorporation.
To address those NCRs or CNCRs that were written prior to implementing the above noted programs, the following is offere? as a brief outline describing the actions which we believe are appropriate:
A. For the contractors currently working on-site, incorporation will not be a problem because they have yet to start turning over as-built drawings. However, the aforementioned Bechtel letter will instruct the contractors that the requirements previously noted are retroactive and that they must backfit where necessary to achieve compliance.
B. The question of required changes, as a result of past NCRs and CNCRs for those contracts already closed, will be included in a program to be developed by UE&C Engineering whereby all past "Use-As--
Is" and " Repair" NCRs and CNRCs will be reevaluated to determine if they affected design and, therefore, should have been incorporated into as-builts and if in fact they were. Those NCRs and CNCRs which were not incorporated on the contractor as-built drawing, but should have been, will be identified by UE&C Engineering and incorporated in the design drawing as-built. Those that affect UE&C design drawings will be processed in accordance with the aforemen-tioned UE&C procedures. It is anticipated that a complete review of all past NCRs and CNCRs will be completed on or before December 1984.
F.
Date of Full Compliance Revision of the contractor procedures to include as-builting of all "Use-As-Is" and " Repair" NCRs and CNCRs will be completed by April 1982. Establishment of a program to review all past "Use-As-Is" and
" Repair" NCRs and CNCRs will be in place by July 1,1982, with a review completion date of December 1, 1984.
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3y, STATE OF WASHINGTON )
- ss COUNTY OF BENTON )
D. W. Mazar, being first duly sworn, deposes and says:...That.he.is.the Program Director, WNP-1/4, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authorized to submit the foregoing on behalf of said applicant; that he has read the foregoing and knows the conte.ts thereof; and believes the same to be true to the best of his knowltjge.
DATED this ll-d day of Feb. ,1982.
Yhl D. W. MAZ U On this day personally appeared before me D. W. MAZUR to me known to i
be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and pur-poses therein mentioned.
GIVEN under my hand and official seal this ) \ day of pmhtb . , 1982.
N M d . M o_ % u x Notary Public in and for the State of Washington, residing at: K4% w A i
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