ML20052B143
| ML20052B143 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 04/13/1982 |
| From: | Haist D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20052B137 | List: |
| References | |
| 50-508-82-04, 50-508-82-4, NUDOCS 8204300075 | |
| Download: ML20052B143 (3) | |
Text
.
APPENDIX A D0TICE OF_ VIOLATION Washington Public Power Supply System Docket No. 50-508 P. O. Box 1223 Construction Permit No. CPPR-154 Elma, Washington 99541 As a result of inspections conducted on March 1-5 and 15-19, 1982 and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C),
47 FR 9887 (March 9, 1982), the following violations were identified:
A.
10 CFR 50, Appendix B, Criterion II states that:
"The quality assurance programs shall provide control over activities affecting the quality of the identified structures, systems, and components, to an extent consistent with their importance to safety."
Paragraph 17.1.2 of the Ouality Assurance Program documented in approved PSAR Deviation No. 26-WP, states, in part, that:
"The Supply System requires its Quality Class I contractors...to establish and implement Quality Assurance Programs consistent with the applicable criteria of 10 CFR 50, Appendix 8."
UPPSS Quality Assurance Requirement No. QAR-2-2, Rev.1, paragraph 2.1 states, in part, that:
" Quality Class I items are required to meet the applicable provisions of 10 CFR 50, Appendix B.
Ebasco Specification No. 3240-213 entitled " Steel Containment Vessel" is classified as a JPPSS Quality Class I specification.
Paragraph 1.1 of this specification states, in part, that:
"The Containment Vessel includes... dome inspection walkway and handrail...all in accordance with this specification as shown on the following contract drawings:
1.
3240-G-3500 Reactor Building Primary Containment Vessel-SH 1...."
Ebasco drawing no. 3240-G-3500, SH 1, Rev. 8, " Reactor Building Primary Containment Vessel" as approved for construction is labeled "WPPSS Quality Class I" and depicts the done inspection walkway and handrail to be supplied by the 213 contractor.
Contrary to the above, on '1 arch 5,1982 the ir.spector observed undersized welds, e.cessive undercut, and partial penetration welds in lieu of the required full penetration welds on installed and painted portions of the Unit No. 3 done inspection platform from elevation 579'-0' to 595'-0".
It was thereafter determined that these structures had been fabricated and installed in accordance with Chicago Bridge and Iron Quality Classification "D" as approved by Ebasco on Chicago Bridge and Iron Drawing No. 74-3431 Rev. 6 (Ebasco No. 3240-29307, Rev. 6) even though an analysis had not been performed to determine th&t the failure of the structures would not significantly affect safety-related components. Chicago Bridge and Iron Quality Classification "D" does not satisfy WPPSS Quality Class I and 10 CFR 50, Appendix B requirements.
8204300015
' This is a Severity Level IV Violation (Supplement II)~ applicable to Unit 'lo. 3.
R.
10 CFR 50 Appendix R, Criterion V, states, ir, part, that:
" Activities affecting quality...shall be accomplished in accordance with... procedures.
Paragraph 17.1.5 of the Quality Assurance Program documented in approved PSAR Deviation No. 26-N'P, states, in part, that " Contractors and vendors, including Ebasco...are required to have written... procedures.'..which govern their quality related activities....*
Ehasco Procedure 'h. PSP-RE-2-36, Rev.1, " Initiation and Processing of Droject Change Proposals" includes the following requirements for the issuance and control of quick f1x project change proposals (0FPCP):
" Originator-Completes section 1 through Paragraoh 3.3.2.3 19 as appropriate on the QFPCP form."
Section 2 of the OFPCP form requires affected drawings and specifications to be listed.
Paragraph 3.3.1.1 "The proposal must address specific changes to design drawings...."
Paragraph 3.3.2.7
" Resident Engineer / Discipline-Assures adequacy of technical direction and that all contracts affected by the technical direction are identified on the QFPCP."
"For voiding of Design Change CFPCP's, Paragraph 3.3.1.10 see paragraph 3.2.8."
Paragraph 3.2.9(a) -
"If an approval S-TP or OFPCP is not to be replaced, the modification shall be voided by the issuance of a DSCN in accordance with Reference 4.3."
Paragraph 3.2.8(h)
"If the technical information on S-TP or 0FPCP requires revision, a superceding document modification may be prepared which indicates the voided document modificat' ion number in the appropriate.
block of the form. Supersession shall not be partial but shall void the superceded document in its entirety."
Contrary to the above, the following procedural noncompliances were identified on March 18, 1982:
. Quick fix project change proposal (QFPCP) No. 35Q-06681 dated February 24, 1982 was issued without listing Ebasco drawing No.
63510 SH 3, Rev. 4 as an affected design drawing.
OFPCP No. 35Q-06723 dated February 25, 1982 was issued _without listing Chicago Bridge and Iron drawing nos. 3272-409, SH 1, Rev. 4 (Ebasco No. 3240-37090 Rev.1) and 3272-409 SH 2, Rev. 4 (Ebasco Mo. 3240-37091 Rev. 1) as affected drawings.
1FPCP No. 350-06723 did not identify the section detail affected by the design nodification.
9FPCP No. 351-06723 did not identify that contract no. 3240-113 was affected by the design modification.
OFPCP No. 350-06681 was cancelled on February 26, 1932 and superceded by 0FDCP No. 350 n6723. A DSCN was not issued ~to void QFPCP No. 351-06681 nor did QFPCP No. 351-06723 indicate that it superceded GFPCP No. 351-06681.
. As a result of these procedural noncompliances, the construction contractor's controlled drawing file contained the cancelled QFPCP No. 35Q-06681 j
posted as a modification to the applicable Chicago Bridge and Iron-detail drawing. The design modification contained in QFPCP No. 350-06723 was being implemented although not posted as a modification to the applicable Chicago Pridge and Iron detail drawing.
This is a Severity Level 'l Violation (Supplement II) applicable to Unit 3.
Pursuant to the provisions of 10 CFR 2.201, Wishington Public Power Supply System is hereby required to submit to this office within thirty (30) days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
' lith respect to iten A, please include your findings as to whether other structures have also been fabricated and installed in error to the Quality Classification "D" rather than nuality Class I requirements by this contractor.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be subnitted under oath or affirmation. Consideration may he given.to extending your response time for good cause shown.
F R 1.3 B B2.
D10 {
Date Dennis P. Haist Reactor Inspector m'_
m
.--