ML20041E208

Responds to NRC 820111 Ltr Re Violations Noted in IE Insp Repts 50-508/81-19 & 50-509/81-19.Corrective Actions:Joint Venture Project Engineering Dept Reviewing All Completed QA-034 Forms

ML20041E208
Person / Time
Site:	Satsop
Issue date:	02/12/1982
From:	Leddick R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Faulkenberry NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20041E201	List: ML20041E208
References
GO3-82-140, NUDOCS 8203100248
Download: ML20041E208 (6)

Text

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jf Washington Public Power Supply System Box 1223 Elma, Washington 98541 (206)482-4428 Docket Numbers 50-508 and 50-509 February 12, 1982 G03-82-140 nma U. S. Nuclear Regulatory Commission, Region V Office of Inspection and Enforcement 1450 Maria Lane, Seite 260 Walnut Creek, California 94596-5368 Attention: Mr. B. H. Faulkenberry Chief, Reactor Construction Projects Branch

Subject:

NRC INSPECTION AT WNP-3/5 ITEM 0F NONCOMPLIANCE IE REPORT N0.50-50c,/509/81-19/01

Reference:

NRC letter, dated January 11, 1982, Mr. B. H. Faulkenberry to Mr. R. S. Leddick, NRC Inspection at Washington Nuclear Proje::t Nos. 3 and 5, (WNP-3/5).

The referenced letter reported the results of the NRC inspections cond9cted by Mr. W. G. Albert on November 1 - 30, 1981, of activities authorized by NRC Construction Permit Nos. CPPR-154 and 155. One Item of Noncompliance (81-19/01) concerning a failure to follow procedures for the control of weld filler material was identified.

Attached is a report detailing corrective / preventive actions taken for the subject noncompliance. The Supply System concurs with the corrective actions taken and wil'1 consider the violation satisfactorily resolved when full com-pliance is attained by February 14, 1982.

Should you have any questions or desire further infonnation, please contact me directly, s

/ .

R. S. Leddick, 1000 Program Director, WNP-3/5 DRC/tt MU::Cu cc: Mr. d. A. Adams - NESCO 91 :ll gy g g""gy El Mr. D. Smithpeter - BPA Ebasco - New York WNP-3/5 Files - Richland g;g OMG35U 8203100248 820302 PDR ADOCK 05000508 0 PDR G). -30

, R. S. LEDDICK, Being first duly sworn, deposes and says: That he is the Program Director, WNP-3/5, fer the WASHINGTON PUBLIC POWER SUPPLY

. SYSTEM, the applicant herein; thht he is authorized to submit the fore-going on behalf of said applicant; that he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge.

DATED /1Mdk ,1982.

c T

j R. S. LEDDICK i

STATE OF WASHINGTON )

) ss COUNTY OF GRAYS HARBOR )

On this day personally appeared before me R. S. LEDDICK to me known to

! be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and pur-poses therein mentioned.

GIVEN under my hand and seal this _ l.3th dayofFeseunm<t-,1982.

6

O wCCLa NotaryPubikcinandfortheState of Washington Residing at G.LmA

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DOCKET fl0. 50-508 i l

C0f4STRUCTI0ft PERf1IT f40. CPPR-154 fluclear Regulatory Commission - tioncompliance (50-508/81-19-01) 10CFR50, Appendix B, Criterion V states in part: " Activities affecting quality shall be..." A required quality affecting activity is defined by Criterion VIII of Appendix B which states in part that "... measures shall assure that identification of the item is maintained by heat num-ber, serial number or other appropriate means."

Section 17.2.8 of the WilP-3/5 PSAR in turn states that, "The Ebasco Qual-ity Program requires that identification and traceability during construc-tion be maintained when required by code, standard or specification." The governing specifications established by Ebasco for control of weld filler materials are 884-WA-80, 884-WB-80 and 884-WC-80. Section 5.2 of each of these specifications requires the use of Ebasco approved procedures for weld filler material identification and control. The approved procedure utilized by the Morrison-Knudsen Co. under their Joint Venture Contract tio. 3240-224 is FWP 500fi, titled Filler Metal Procurement and Control .

Contrary to the above requirements, an f4RC examination of this subject on

- flovember 27, 28 and 30,1981, found that certain provisions of procedure FWP 500fl were not being properly implemented as listed below:

1. Section 7.3.1 requires the use of form QA-034 for the requisition of weld filler materials from the warehouse and specifies three copy dis-tribution to the welding engineer, warehouse and QA records. Contrary to this, it was found that only two copies were used with distribution to QA records and field wire rooms.

2. Section 7.4.1 requires that an approved access list be posted in each field wire room. Contrary to this, the field wire room in the west lay-down area serving the pipe fabrication shop (west wire room) had out-of-date lists posted as evidenced by entry of personnel who were not on the list but performed the function of those who were listed.

3. Section 7.4.4 requires that bare wire and consumable inserts be kept dry and packaged until required for issue. Contrary to this, it was noted that a coil of bare wire was not packaged and that a coffee urn was in use near the bare wire storage in the west wire room.

4. Section 7.4.6 requires that all spooled wire for the GTAW process shall be placed on pallets or shelves. Contrary to this, two stacks of spooled wire were found on top of sealed cans of coated electrodes in the west wire room.

5. Section 7.4.8 requires that the oven or slot in the oven be labeled with the applicable information for the material being stored. Contrary to this, a label on the outside of one oven of the west wire room belonged on another oven and one oven with two types of weld electrodes did not have slot identification.

Page 2 Nuclear Regulatory Commission 'oncompliance (50-508/81-19-01) (Continued)

6. Section 7.5.2 reov6 that a pink copy of form QA-35 (rod withdrawal authorization) at .hpany each portable container. Contrary to this, it was found that the west wire room would use a single form when both coated and bare filler wires were issued to a single welder. There-fore, one container could not meet the requirement. This was specifi-cally noted with regard to an issue of E705-2 wire to welder T-16 on November 30, 1981 from the west wire room.

7. Section 7.4.11 requires that all GTAW welding wire be used in capped containers. Contrary to this, GTAW weld wire issued for welder T-16 on November 30th did not ha*. a cap on the container.

This is a Severity Level V violation applicable to Unit 3 only.

CORRECTIVE ACTIONS TAKEN The following corrective actions have been taken for each of the provisions of procedure FWP 500N that were identified as not properly implemented:

ITEM 1 - Form QA-034 required a three copy distribution, while the form in use only had two copies.

Corrective Action:

1. A three part QA-034 form was ordered and put in use on Decem-ber 2,1981.

2. The Joint Venture (Contract 224) project welding engineering department is presently reviewing all completed QA-034 forms to assure a copy of each completed QA-034, since the date of the first issue from the warehouse, is available at each re-quired area. For QA-034 forms that do not have a pink copy available for the QA Record Vault, xerox copies will be taken from either warehouse or engineering files and marked "QA Record Copy" and placed in the QA Records Vault.

ITEM 2 - The field wire room in the west laydown area had an out-of-date approved access list posted.

Corrective Action:

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1. The project AGS Welding Superintendent has committed to updat-ing the weld wire room access list in pen, with his initials and date. The list will be retyped and reissued on a monthly basis or as needed and distributed to each of the weld wire rooms.

2. An internal audit (MKP-003) encompassing weld filler metal con-trol was conducted January 4-15, 1982. As a result of the audit, the wire room access lists were found to be current and properly posted.

Page 3

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. l CORRECTIVE ACTIONS TAKEN (Continued)

ITEM 3 and ITEM 4 -

A coil of bare wire was not packaged and a coffee urn was in use near the bare wire storage in west laydown area. Two stacks of spooled wire were found on top of sealed cans of electrodes.

Corrective Action:

1. The west wire room has been re-built to separate the wire room from other activities. Correct shelving has been in-stalled and bare wire, consumable inserts, and spooled wire have been properly stored.

2. An internal audit (MKP-003) encompassing weld filler metal control was conducted January 4-15, 1982. During this audit, the field wire rooms were found to be in compliance with the storage requirements of FWP 500N.

ITEM 5 - In the west wire room, a label on the outside of one oven be-longed on another oven and one oven with two types of electrodes did not have slot identification.

Corrective Action:

All storage ovens have been properly marked with weld filler metal identification for each oven slot. Identification will be maintained through the use of storage oven maps attached to the respective oven.

ITEM 6 - The west wire room was using one QA-035 form for issue of both

, coated and bare filler metal making it impossible for the pink copy to accompany each container.

Corrective Action:

1. All wire room attendants and superintendcnts have been in-formed that only one type of filler metal may be on a QA-035 form.

2. An internal audit (MKP-003) encompassing weld filler metal control was conducted January 4-15, 1982. During the audit, the deficient condition was found to be satisfactorily correc-ted.

ITEM 7 - GTAW weld wire was issued without a cap on the container.

Corrective Action:

I 1. Containers with tighter fitting caps are now being used by both field wire rooms for issue of GTAW weld wirt.

- - Page 4 CORRECTIVE ACT*0NS TAKEN (Continued)

ITEM 7 - Corrective Action: (Continued)

2. An internal audit (MKP-003) encompassing weld filler metal control was conducted January 4-15, 1982. During this audit, the deficient condition was found to be satisfactorily correc-ted.

ACTION TAKEN TO PREVENT RECURRENCE The following preventive actions were taken to preclude recurrence of the deficiencies identified in the item of noncompliance.

1. A two hour training session was conducted on December 3,1981 for all personnel associated with the implementation of FWP 500N. The training session included:

- A discussion of the course and corrective action associated with the NRC finding.

- Explanation of responsibilities related to FWP 500N.

- Emphasis en verbatim compliance to procedures.

- A walk-through of the critical portions of FWP 500N.

2. As a result of the discrepancies encountered by the NRC and reported as ITEM 5, the following actions were taken:

- A training class for all personnel associated with weld filler metal storage was conducted on January 27, 1982.

- A procedure change (PCN 128) and subsequent revision (PCN 128, Rev.1),

clarifying holding oven storage requirement: and filler metal issue ,

requirements, was submitted to Ebasco for review and concurrence. Upon receipt of the PCN, additional training of all cognizant personnel will be conducted. Training will be conducted by February 14, 1982.

DATE OF FULL COMPLIANCE Full compliance will be achieved by February 14, 1982.