ML20054J324
| ML20054J324 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 05/28/1982 |
| From: | Dodds R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20054J310 | List: |
| References | |
| 50-460-82-06, 50-460-82-6, 50-513-82-04, 50-513-82-4, NUDOCS 8206280489 | |
| Download: ML20054J324 (21) | |
See also: IR 05000460/1982006
Text
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION V
Report Hos. 5_0-460/82-06, ~20-513/82-04
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Docket Mos. 50-460/bi3
License Nos. CPPR-134/174
Licensee:
Washington Public Supply System
P. O. Box 968
Richland, Washington 99352
Facility Nane: Washington Nuclear Project No.1/4 (WNP-1/4)
Inspection at: WNP-1/4 Site, Benton County, Washington
Inspection conducted: April 1-30,1982
Of 2S[b 2
Inspector:
N
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A. D. Toth, Senior Resicent Inspector
Date Signed
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5/26[OL
Approved by:
cm
<ta
R. T. Dodds, Chief -
Date Signed
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Reactor Construction Projects Section 2
Unit #1 Summary:
Inspection April 1-30, 1982 (Recort No. 50-460/82-06)
Areas Inspected:
Routine, unannounced insoection of reactor coolant loop piping,
welder aualifEation, safety-related pipe supports and restraints, piping nondes-
tructive examination orocedures, piping welding, and licensee actions on previous
insoection findings. The insoector also inspected mechanical contractor handling
of nonconformance reports, electrical contractor field engineer qualifications,
and concerns expressed by three site personnel. The inspection involved 95
inspection hours on-site by the senior resident insoector.
Results: Of the 10 areas inspected, items of noncompliance were identified in
3 areas.
(Insufficient penetration of shop weld of pipe rupture restraint,
Para. 6; Omission of records of weld inspections of conduit supports, Para. ll.b;
Inadeauate protection of equipment, Para.12.j.)
Unit #4 Summary:
Inspection April 1-30, 1982 (Report No. 50-513/82-04)
Areas Inspected:
Routine, unannounced inspection of the maintenance of facilities
and equioment during the project termination state. The inspection involved 1
inspection hour on-site by the senior resident inspector.
Results:
No items of noncompliance were identified.
8206280499 820600
PDR ADOCK 05000460
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DETAILS
1.
Persons Contacted:
Washington Public Power Supply System
- G. Dyekman, Design Engineering Manaaer
- G. Edmondson, Power Engineering Supervisor
- C. Edwards, Project Quality Assurance Manager
- M. Farrell, Ouality Assurance Specialist
- L. Oakes, Senior Mechanical Engineer
- C. Organ, Assistant Program Director, Engineering
- M. Rodin, Quality Compliance Senior Quality Assurance Engineer
- R. Root, Acting Program Director WNP-1
United Engineers and Constructors
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G. Faust, Field Surveillance Quality Assurance Supervisor
M. Lasota, Field Project Engineer (Piping Supports)
Bechtel Power Corporation (BPC)
W. Clayton, Quality Control Supervisor, Mechanical
E. Edwards, Project Manager
T. Fallon Project Ouality Control Engineer
- J. Gatewood, Project Field Quality Assurance Engineer
D. Johnson, Manager of Quality
- C. Kasch, Quality Control Supervisor
T. Psomas, Preventive Maintenance Quality Control Supervisor
A. Abuhaydar, Quality Assurance Auditor
C. Rudd, Quality Assurance ~ Auditor
- J. Rudd, Quality Assurance Engineer
D. Webb, Preventive Maintenance Supervisor
J. A. Jones Construction Comnany
C. Anderson, Assistant Project Quality Assurance Manager
J. Dale, Quality Verification Lead Inspector, Containment
T. Daines, Welding Engineer
D. Higginbotham, Senior Quality Assurance Supervisor
D. Plowman, Field Engineer
J. Stannard, Lead Welding Engineer
R. Wilson, Quality Assurance Manager
Foley, Wismer & Becker Comoany
L. Adams, Project Manager
R. Jones, Quality Assurance Manager (Resigned)
L. Maenpa, Director of Quality Assurance
C. Needham, Engineering Manager
R. Wetle, Quality Assurance Manager
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Bonneville Power Administration
D. Blacketer, Site Representative
Other General Contacts and Notes
In addition to the persons identified above, the inspector interviewed
many other personnel from the construction, engineering, and auality
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control site contractor organizations. He interviewed.various craft
and supervision who were present in the work areas during the inspector's
activities, or who had visited the inspector's office.
- Denotes personnel present at the exit management meeting.
2.
Gen.ral
The resident inspector was on-site April 1-2, 5-9, 12-16, 19-23, 26-28,
and 30. During this period, the inspector performed routine examinations
of activities, including plant tours, record reviews, and interview of
personnel. He interviewed several craft and inspection individuals
regarding any quality concerns which they may have and the applicability
of NRC regulations to their work.
Two NRC reqional office inspectors were on-site the week of Anril 26.
Their activities are documented in a separate report.
3.
Significant Project Events Noted
On April 19 the Bonneville Power Administration administrator
recommended that the construction of WNP-1 be temporarily susnended for
a period of 2 to 5 years. This was related to a shortage of cash on hand
at the _ Supply System and obstacles to obtaining additional funds.
WPPSS executive board meetings were held on April 23, 28 and
29, at which time the recommendation was accepted. Direction was
issued to the site contractors to ramp down activities at the WNP-1
site. The innediate project plan is to commence reductionssin force
to a level of about 1050 by September 1,1982, if not sooner.
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4.
Unit #4 Layup' Quality Assurance
Inspection Objectives
Ascertain whether extended construction delay activities are being
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accomplished in accordance with NRC requirements and licensee commitments.
(Emphasis is on preservation of materials and associated records'which
may be dispositioned to other facilities licensed by NRC.) Observations ~
and evaluations were to generally consider the following:
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a.
Protection and oreservation (where applicable).
b.
flonconfonning activities and conditions.
c.
Utilization of inspection personnel.
Inspection Approach
The inspector addressed the inspection objectives relative to the
preventive maintenance operations at the off-site Pasco warehouse.
The
Bechtel preventive maintenance quality control inspector assigned to the
Pasco warehouse, and her supervisor, stated that all preventive maintenance
cards for April had been completed and submitted to the connuter entry
group; new cards for May had not yet been issued.
Findings
fio items of noncompliance were identified.
5.
Reactor Coolant Piping Welder Qualification
Inspection Objectives
Determine whether welders and welding operators were adequately qualified
to weld reactor coolant pressure boundary piping in accordance with the
ASME Boiler and Pressure Vessel Code, as well as other licensee and/or
contractor requirements. This included determining whether:
a.
The licensee / contractor has established procedures for qualification
of welders and welding operators in accordance with the ASME Code, as
applicable.
b.
The licensee / contractor has an adequate system for maintaining a
continuous record of the qualification status for all welders and
welding operators and whether this systen is effectively utilized
and accurate.
c.
Welders and welding operators have been and are currently qualified
to weld under the respective procedures.
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d.
The qualification status records are accurate and conform to the
applicable Code requirement .
e.
The qualification status records involved in weld repairs meet
applicable aualification requirements.
f.
For the following activities, Code requirements have been complied
with:
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(1) Completion of the qualification test weldment.
(2) Layout, removal and preparation.of bend-test specimens from the
qualification weldment.
(3) Performance of mechanical or nondestructive testing of samples
removed from the nualification weldment.
(4) Evaluation of the mechanical test samples or review of
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radiographs used for examination of the test weld.
Inspection Approach
The inspector addressed all inspection objectives. The inspector examined
J. A. Jones procedures which govern qualification testing and certification
of welders, and which provide for maintenance of qualification status
(WQ-1 revision 6-0C-1 and P0P-5054).
The inspector interviewed personnel, including: The responsible welding
engineer clerk, a welding engineer, the ASME Code inspectors, a typical
welding foremen, welder ZL regarding his training and indoctrination,
the test-booth supervisor and foreman, and a WPPSS surveillance auditor
who had currently completed a review of welder qualification activities.
The inspector examined records including: The radiograohs for the
qualification of ZL; the welder status log and " Welder Performance
Qualification Record" for four welders who had performed welds on the
reactor coolant system and for four welders who had performed repairs on
welds, base metal or cladding of the reactor coolant system; training and
indoctrination records relating to site work and welding procedures,
including viewing of an 80-minute video training film regardi_ng ASME
Section III requirements.
Records for the following welders and welding
operators were reviewed:
Welder
Ueld/ Repair Location
Weld Procedure
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FW19 Reactor Vessel
Pl/P3-3(I)
A7
FW19 Reactor Vessel
P1/P3-3(I)
HK
FW22 Steam Generator
Pl/P3-3(I).
V0
FW05 Steam Generator
P1/P3-1
FW14 Reactor Pump
P8-3
Z1
FWO4 Steam Generator
Pl/P3-3(I)'
FW21 Reactor Pipe
Pl-2A
AN
FWO9 Reactor Vessel
P1/P3(clad)_A8-2A
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The inspector observed and examined: welders ZK and ZL in the weld test
booth; the test-specimen' radiography shielded room; and the test specimens
for ZK, ZL and several others. The inspector considered the allocation of
resources to the welder qualification effort, and the evidence of
implementation of Code and procedure requirements.
Findings
The inspection objectives were accomplished. The inspector noted that
welder qualification test sample examinations are done using the
radiographic examination option provided in the ASME Code, with bend
test or mechanical test specimens generally not used, except for cladding
welding.
No items of noncompliance were identified.
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6.
Safety-Related Pipe Suonort and Restraint System
Inspection Objectives
Ascertain whether work activities for safety-related pipe support and
restraint systems are being accomplished in accordance with the PSAR and
applicable codes, standards, and specifications, relative to dynamic pipe
supports. This included selection of a. total of ten snubbers, shock
suppressors or restraints, at least two for each of three different load
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classifications, and observation of the following,-prior to installation:
a.
For mechanical; type snubbers, check shaft travel for smoothness by
simulating normal operation by pulling and pushing the snubber shaft;
also, Ilmulate unit; activation by sudden movement.
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The inspector addressed all inspection objectives relative to mechanical:
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snubbers. The inspector discussed the operability check with the Bechtel
supervisor of receiving inspection and preventive maintenance, who
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assisted in the examination of the~ following _ ten mechanical type specific. .i
snubbers at the warehouse receiving inspection area:
Identification
Load Rating
FWS-78-RM-2
350 #
MUS-121-RM-109A
350 #
SGC-4-RM-2
350 #
DHR-54-RM-10A
1500#
MSS-369-RM-3
1500 #
MSS-6-RM-4
1500 #
DHR-9-RM-4
6000 #.
CCW-54-RM-105A
6000 f
CFS-10-RM-5
6000 #
FWS-7-RM-108-
15000 #
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Findings
No items of noncompliance were identified.
The inspector also followed a delivery truck onto the site and observed
off-loading of pipe-support components. This included the observation of
the cuality control receiving inspector activities, and the off-loading
and record receipt activities. An associated tcur of the lay-down yard
identified stainless steel pipe-whip hoops and restraint components. The
inspector measured the weld penetration of an accessible shop-weld on
pipe whip restraint MSS-PW-3-2; the measured penetration of 7/16-inch
over a 10-inch length did not appear to meet the 3/4-inch penetration
specified on Detail B-B of drawing F435860, nor that on the pipe support
design calculation sheet. The associated vendor records for this component
(Corner & Lada Company, Incorporated) included NDE Examination Records;
these note acceptance of visual and magnetic particle examination of each
tack-weld and production weld. There was no notatien of any unacceptable
weld joint fit-up or inadequate welding, relative to the observed
condition.
When notified by the inspector, the construction manager assigned
insoection personnel who confirmed the inspector's measurements and
prepared Bechtel Nonconformance Report 1-BNCR-151-02, dated April 21, 1982.
The BNCR also identified two other defects on the vendor supplied material.
The failure to fabricate the pipe whip restraint in accordance with design
drawings appears to be an item of noncompliance.
(460/82-06-01).
7.
Pioing Quality Assurance Procedures for Nondestructive Examination
Inspection Objectives
Ascertain whether quality assurance plans, instructions and procedures
relative to nondestructive examination of welding of reactor coolant
pressure boundary piping and other safety-related piping, have been
established in the facility QA manual, and whether these documents
conform to the QA program as described in Chapter 17 of the facility SAR.
This includes review of the general QA program provisions for audits,
definition of quality requirements, preparation of procedures, control of
material, control of processes, and generation of records.
It also includes review of specific NDE procedures for:
techniques,
conformance to ASME Code requirements, personnel qualification .to
ASNT-TC-1A standards, equipment calibration, control of contaminants in-
NDE couplants and solvents, requirements for application of' the NDE
to evaluation of weld quality, and evaluation of radiograph quality.
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Inspection Approach
The inspector addressed all inspection objectives. The general 0A program
provisions of the installing contractor (J. A. Jones) have been examined by
NRC during previous inspections, including the recent team inspection
(Report 50-460/81-10Part9). The inspector considered the results of
that inspection, which meet the inspection objectives relative to NDE
activities of J. A. Jones.
During examination of individual NDE procedures
he reaffirmed the inc?usion of requirements foY audits and quality record
generation, identification, retrievability, review and approval.
Certain NDE procedures have been reviewed by NRC inspectors at the tise
of reactor coolant loop work activities in 1980 (Report 50-460/80-11).
For the current inspection the inspector ascertained that the LP and MT ~
procedures JAJ-NDE-001 (Rev. 4) and JAJ-NDE-002 (_Rev. 4) have not been
revised. The inspector examined the revisions to the RT and VT
procedures JAJ-NDE-003 (Rev. 5) and JAJ-NDE-002 (Rev. 3)_; the complete
UT procedures JAJ-JDE-005 (Rev. 0), JAJ-NDE-006 (Rev.1), JAJ-NDE-Oll
(Rev. 0) and JAJ-NDE-012 (Rev. 0); the visual inspection procedure
JAJ-NDE-008 (Rev. 7); and the procedure for qualification and demonstration
of NDE procedures JAJ-NDE-009 (Rev. 0).
Findings
The NDE procedures clearly incorporated applicable ASME Section III and
Section V requirements, mostly through direct quotation and reproduction
of applicable data tables and figures.
No items of noncompliance were identified.
8.
Plant Tours (esp. Pipina Welding)
The inspector toured the general services building and the containment
building during various times this report period.
Particular noteworthy
items, relstive to implementation of the quality assurance program and
attention to associated corrective actions, are discussed below:
a.
The inspector routinely encountered welding operations in-progress,
and routinely examined the attendant in-process records, examined the
welding, and interviewed the welders or pipe-fitters regarding their work
and ability to accomplish quality work. The inspector considered the
cleanliness, fit-up, cold spring, purge gas, and other in-process
quality verification sign-offs on the records and/or evidence of
physical acceptability.
For items (2), (3), (4) and (6).below the
inspector ascertained that th'e welder qualification record included
the weld procedure being used in the field.
The following welds
were observed:
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(1) DHR-412029 FW-305, a 12-inch stainless steel ASF Class 2 weld.
(2) FWA-412013 FW-305, a 6-inch stainless steel ASME Class 2 weld.
(3) DHR-412026 FW-001, a 12-inch stainless steel ASME Class 2 weld.
(4) MUS-411499 FW-002, a 4-inch stainless steel ASME Class 2 weld.
(5) MUS-411499 FW-521, a 4-inch stainless steel ASME Class 2 weld.
(6) HSS-412158 a 4-inch carbon steel ASME Class 2 231d.
b.
The inspector observed placement activities for containment building
dome placements C3012 and C3013.
He checked for presence of inspection
personnel, concrete testing, cleanliness of reinforcing steel and
construction joint, sufficiency of equipment and craft personnel, flow
of concrete around reinforcing steel and liner-stiffeners, handling of
vibrators, size of vibrators and distance between insertions. These
matters were considered relative to general concrete practices
defined in ACI and ASME Codes and Standards. Also during the month,
the inspector observed the placement of. cold weather protection over
other recent concrete placements.
c.
The inspector observed a notebook of sixteen work procedures, plus
several copies of specific ones, in the foreman's area of the main
steam isolation area. The procedures were "Information Only" issues.
A hand-written index was included, which was dated just four days prior
to the observation. A check of the. controlled procedure 11ndex showed
that eight of the sixteen procedures were not current.
Bechtel-quality
assurance staff conducted a plant-wide survey of work stations, finding
several similar uncontrolled copies of procedures. They initiated
steps to correct this condition.
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d.
The inspector interviewed craft and examined the field-active work
package for the installation of the-core flood tank CF-TK-28. The-
package was well organized in a loose-leaf workbook.
It showed rigorous
attention to installation of the support legs, including records of -
cutting and rewelding of the legs, shimming, alignment, identification
of damage to lubrite rings, and grouting.
No items of noncompliance were identified.
9.
J. A. Jones Handling of Nonconformance Reports
The inspector had noted occasional worker comments regarding handling of
nonconformance reports by mid-line supervision, and had discussed these
with the Bechtel quality assurance organization. The Bechtel auditors
subsequently audited the contractor voided noncompliance reports files,
and advised the inspector that no discrepancies were found which would
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call for corrective actions. The J. A. Jones quality verification
supervisor had also taken a related action. The supervisor had surveyed
21 of his 57 inspectors to determine if they knew of any cases where
mid-line suprvisors/ leads had refused to process nonconformance reports
generated by inspectors, without documentation of reasons and voiding in
accordance with approved procedures. The supervisor had planned to
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complate this survey of the remaining inspectors but was unable to do so
because of the announced shutdown of the WNP-1 project. For the few
instances identified by the inspectors, the supervisor was fully
cognizant of the details and provided reasonable rationale for the actions
taken.
No items of noncompliance were identified.
10.
Electrical Contractor Field Engineer Qualifications
The inspector had noted occasional comments regarding the youth of the
Foley, Wismer & Becker field engineers, and inferences regarding their
qualifications. The inspector examined the education and work experience
files of the day-shift and second shift field engineering staff who
prepare field routing of conduit. The position descriptions ranged from
draftsman trainee to senior engineer. These personnel are responsible for
consideration of circuit separation criteria described in work procedures,
when establishing field routing of conduit.
Highly technical engineering
work did not appear to be part of their work activity. The org'anization
included a spectrum of personnel, ranging from five years college and
several years technical experience to high school graduate and no
technical experience. Many of the individuals, especially those in the
draftsman / trainee category, were about 20-years age.
Both shifts
included a balance range of personnel qualifications. There are no
specific NRC minimum qualification criteria for engineering personnel.
The inspector identified no cause to question the noted personnel
qualifications.
No items of noncompliance were identified.
11.
Employee' Concerns
The inspector inquired into matters which were brought to his attention
by site employees or other unidentified individuals:
a.
Preventive Maintenance of Air Handling Equipment
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An individual reported his opinion that Bechtel personnel were not
properly performing preventive maintenance of heating and ventilation
equipment. He mentioned the following three items as examples, in
addition to some non-safety-related items:
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(1) Air handling unit MER AHU-3, at elevation 501 of the general
services building, was dirty and the coils and filters were
damaged.
The inspector toured the entire 501-elevation with the Bechtel
preventive maintenance quality control supervisor, within a
half-hour of receipt of the complaint. The interior of each
air handling unit was inspected.
Some minor dirt and: trash
appeared in several units which were in various stages of
erection.
Some minor denting of radiator-fins was apparent at
local spots of several coils. The observed conditions appeared
to be insignificant for the current stage of installation.. No
unit MER-AHU-3 was identified in the area, nor did it appear on
the computer list of equipment.
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(2) There were rumored plans to omit one nonth of preventive
maintenance by combining the April and May control cards for
heating and ventilation equipment...
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The inspector interviewed the Bechtel preventive maintenance
supervisor,.who acknowledged direct responsibility for the
compilation and issuance of the control cards for such work.
He stated that there are no plans to reduce the frequency or
scope of any elements of the preventive maintenance program,
and no plans to combine the April and May activities.
(3)
In general, preventive maintenance of air handling equipment
may not be done properly.
The inspector's tour of the 501 elevation showed that heaters
were activated on motors of fan units, the ~ fans turned freely,
completed and assembled cubicles were generally closed and free
of trash, and partly assembled units contained only nominal dust
and fabrication debris. There did not appear to be any storage
of material in manners which would impact on or damage the
roughing filters, frames, or coils. The inspector identified no
conditions to prompt him to request any corrective action or
evaluation.
No items of noncompliance were identified.
b.
Control of Conduit Installation Activities _
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An anonymous note described questionable quality assurance program
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practices of the electrical contractor. The questions appeared to
be related to similar matters already under consideration by NRC,
i.e. design control and procedure change controls (NRC item 460/82-03-06).
The note alluded to the following specific items:
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(1) Conduit installation using unapproved procedures.
(2) Conduit installation using unapproved design.
(3) Management failure to implement stop work recommendation by
the construction managers staff, (Bechtel).
(4) Resignation of an individual named Bob, due to the above.
These allegations were subsequently fully substantiated by the
NRC resident inspector, as described below:
The resident inspector interviewed personnel, reviewed procedures,
and examined records relating to conduit and cable tray installation,
to ascertain implementation of the design control, document control,
procedure adherance, and corrective action control aspects of the
quality assurance program. He identified an individual Bob, as being
the quality assurance manager for the electrical contractor, who had
left the company on March 1, 1982. The inspector interviewed this
individual off-site on April 16.
The inspection showed that the contractor management had issued
work instructions which were contrary to the work procedures which
had been approved by the_ licensee's representative, UE&C. These
instructions were used as a basis for omitting detailed records of
weld inspections and reference to explicit acceptance criteria for
such inspection. They also allowed field changes to proceed on a
risk basis, pending subsequent approval by UE&C, the design engineer.
Bechtel auditors involved in a combined routine and special audit
had identified the above discrepancies, and had reconnended stop
work to their supervisor on March 26; (however, action was not
taken by the supervisor nor the contractor until April 16, after
questions raised by the MC inspector.) This matter was also
raised by a WPPSS special auditor who was involved in a routine-
unannounced audit of the electrical contractor during March; he
presented his findings to the contractor at a meeting April 1.
This
matter was also generally recognized by two special outside auditors
on March 19 (who had been called in by FWB management as a result
of the resignation of the Quality Assurance Manager on March 1).
None of these audit teams collaberated nor communicated with each
other.
At the time of the receipt of the allegati6ns, the.various audit
report findings had not yet been issued to the contractor in
documented form, although the findings had been conveyed to
numerous responsible management personnel as early as March 26.
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The electrical contractor's Quality Assurance Manager offered his
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resignation on March 1, which was promotly accepted by his
management.
His resignation stated that the quality program was
"so far out of control that our (Foley)-Quality program is a farce".
Direct questioning of him, his management, the Bechtel quality
assurance management, and the WPPSS quality assurance management
(and various staff members) revealed that no attempt has been.made
between February 26 and April 16, to ascertain any details or-
further explanation of his reasons for resignation. 'During the
April 16 interview with the NRC inspector, this individual identified
his principal reasons for resignation. These included having. received
management instructions contrary to customer approved procedures,
including working to design changes which had not yet been approved
by the customer.
The above situation is associated with the fact that the FWB management
had issued internal instructions (e.g. QCI-98) which were not consistent
with the procedures (e.g. QCP-9, QCP-5A) which had been approved by
UE&C. These internal instructions were then used by FWB management
as a basis to instruct personnel to not perform the documentation
prescribed by the approved procedures. The required " Weld Inspection
Sheets" were not prepared for conduit supports IC30H-3418-ADA and
IC30H-3418-ADB.
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The FWB management failed to correct the situation when it was identified
first by the FWB QA Manager (who resigned) and then by the various
auditors. The Bechtel quality assurance management also failed to
promptly initiate corrective action following identification and
recommendation of this matter by the Bechtel and WPPSS auditors.
The
contractor, the construction manager, and the licensee each failed to
inquire into the circumstances of the resignation of the quality
assurance manager and the details of his documented concerns.
This matter represents a deficiency in the licensee quality assurance
program, involving failure to conduct adequate audits or take prompt
corrective action on the basis of such audits.
However, there was no
associated evidence of any examples of deficient construction or
construction of unknown quality due to inadequate program implementation.
The procedural matter was identified by the licensee, was of low
severity level, and did not require reporting to NRC. However, it was
not corrected (including steps to prevent recurrence) within a
reasonable time. This appears to be an item of noncompliance.
(460/82-06-02).
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c.
Union Review of Quality Control Inspector
The piping inspectors and the pipefitters belona to the same local
union flo. 598 of the Plumbers and Steamfitters Union. The
flRC resident inspector heard of a case where a J. A. Jones pipefitter
had filed formal charges with the local union against an inspector,
in accordance with the union's national constitution. The inspector
interviewed a quality control union steward on-site, the quality
verification supervisor, and the quality assurance manager relative
to this matter. The interviews revealed that such an event had
occurred and was resolved.
In the Turbine generator building and main steam isolation area
a problem with J. A. Jones welding material control had been experienced;
the company management assigned a quality control inspector in each
weld material distribution area to assist in assuring that material
was handled in accordance with procedures.
In one area, the attendant
had issued a piece of weld material to a welder for use as a spacer.
The material was taken from the trash barrel under protest of the
inspector. As a result of the inspector reporting the matter in
accordance with his procedures, the pipefitter was apparently fired.
or disciplined.
He then filed charges with the. union against the
inspector. The matter was apparently voted upon at.a union meeting,.
as provided by the union constitution, prior to being referred to the
union Executive Board for consideration. .However,.the inspector was'
apparently an apprentice, and not a journeyman union member; the
Excutive Board referred the matter to the Joint Apprentice Training
Committee (consisting of members of the union and of contractors' ~
management). The Corm 11ttee reportedly congratulated the inspector.
for proper action and dismissed the charges. 'The^ union steward for.
the inspectors stated that the inspectors's representation within
the union is somewhat independent. The NRC-inspector has received
no adverse comment on this matter from on-site union inspectors.
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No items of noncompliance were identified.
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12.
Licensee Action on Previous NRC Inspection' Findings.
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The inspector reviewed l!c.ensee a M ns taken to resolve issues
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identified during previous NRC inspection activities. This involved
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review of records, examination of work, and interview of personnel.
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a.
(Closed) Unresolved Item (460/79-12-04)
Stainless steel piping was supported during installation using wood
pieces which were painted with a fire retardant paint which appeared
to have high chloride levels.
Initial tests by the contractor
indicated high chloride levels; referral ~ to the licensee requested in
questions regarding whether the chlorides were leachable.
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The contractor took another sample and performed a leaching test
as required by the Engineer.
Data examined by the inspector showed
that the painted wood had no leachable chlorides. However, the
associated test data for the bare wood control sample showed
chloride levels of 4500 microgram-per-square-foot, as opposed to the
specification FS-II-2 and specification no. 257 criteria of 1000
microgram-per-square-foot maximum for surfaces of stainless steel
piping. No explanation was established for the apparent high chloride
content of the bare wood. However, in view of the localized nature
of this item, this matter is considered to be encompassed by the
more general question of halogen contamination, as discussed above
in item
"d", below. As a separate matter, the questions of chlorides
-in fire retardant paint of wood blocking is closed.
b.
(0 pen) Noncompliance Item (460/79-13-02)
Field welds contained stainless steel . weld weave widths which exceeded
the 3/8-inch procedural limit for weld technique. A February 19, 1980
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WPPSS reply to the NRC Notice of Violation described corrective actions
which subsequent inspection of December 16, 1980 (Report 460/80-16).
showed to be inaccurate. At that time the inspector requested a
proper amended reply to the Notice of Violation. On July '10,1981
(report 460-81-06) the inspectc* again requested an amended licensee
reply, which the licensee promised by end of July 1981. The promised
amended reply was not issued, and hadonot been issued by April 1982.
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The licensee representative stated that a -period of time transpired _ when
the weld weave width requirement was deleted from the procedures, Land
then later reinstated, such as to require. clarification of the original
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reply. The inspector reiterated the request' to properly amend the.
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formal reply to the notice of violation. 'For current work the inspector
has observed that weld procedures and weld ^ records' include weld weave
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limitations and related quality inspection. ,This matter continues to ,
be unresolved pending the licensee proper clarification of the public
record, and related NRC inspection followup. The li.censee committed to
issue the clarification by June 1,1982.
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c.
(Closed) Unresolved Item (460/79-14-05)
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Welder training and indoctrination appeared to be weak. This matter
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was reviewed with the licensee and documented in prior inspection
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reports (reports 460/80-02 paragraphs 4.c and 7.a, 460/80-08 paragraph
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4.b, and 460/80-15 paragraph 9.) Specific areas of concern included
measurement of preheat and interpass temperature, cleanliness of
piping, and control of heat input during welding.
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Principal welding parameters, such as temperatures and electrical
parameters are defined by the welding engineers on the weld history
records which are provided to the welders in the field for each weld.
More general aspects, such as hold point admonition, cleanliness and
visual acceptance criteria are defined in welder indoctrination sheets
These
which are provided to welders at the qualification test booth.
indoctrination sheets were revised in fiarch 1982 and now provide
The welders are not provided
additional technical information. copies of particular procedures, bu
area and at various field locations.
In January 1981 a 1-1/2 hour video taped presentation was made to
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groups of welders, in a general effort to upgrade training.
video tape was subsequently shown twice each day for the three
week period on July 20-August 7,1981, for the training of all
Current contractor reviews of individual training
records were expected to identify any persons who missed theseT
pipefitters.
previous sessions.of the J. A. Jones procedures, and emphasized previous
matters such as cleanliness, valve seat checks prior to welding,
adherance to procedures, hold point compliance, temporary attachments,
pipe wall thining/ corrosion, availability of procedures in work areas,
material traceability, rigging, and other matters.
During routine inspection and interviews over the past 6-months, the
inspector ascertained that selected welders have received the video an
written indoctrination, procedures are available in the work areas, and
temperature monitoring tools are available and used by typical welders.
Further definition of the craft training program will be
date. This matter is closed.
(0 pen) Unresolved Item (460/80-03-01)_
d.
Stainless steel piping was stored in the general services building at
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elevation-433, in rooms south of the decay heat removal heat exchangers.
The piping was covered with dust from sandblasting, sweeping, concreteTh
form removal, and other construction activity.
of the contaminating materials was unknown, relative
contact with halogen containing compounds such as flourides anddescribed J. A. J
chlorides". Also, NRC inspection report 460/80-04
attempts to obtain WPPSS assistance in controlling c
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and the consequent J. A. Jones disinterest in this topic.
inspection report 80-07 noted that questions existed r
such testing had been deferred.
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Subsequent and current inspections show that little attention is given
to protection of stainless steel piping from surface contamination from
dust, spills of materials, or other surface contamination. Concrete
splatter was observed on piping; (the inspector interviewed the ACME
concrete company quality control representative, and ascertained that
admixture agents and other concrete ingredients contain negligible
chlorides). Significant quantities of bird droppings were observed on
piping; (the inspector interviewed the Bechtel project quality control
engineer who described studies at another Bechtel project, which showed
that such material contains negligible chlorides. The engineer declined
to investigate the matter beyond assuring that the material is removed
from the piping).
There are general specification and procedure' prohibitions regardin~g-
contaminating stainless steel with halogens. 'This, includes controls
on procurements of materials which will be used on stainless steel '
on a planned basis, and cleaning of weld joints prior to welding. .
There are no general site prohibitions against working with high halogen
content compounds within the buildings.
Some'of these materials do
contain high halogen contents, such as the aircraft cleaner-solvent
used by the electrical contractor.
Controls appear to be lacking to
assure that such materials do not contact the stainless steel.
Therefore, this matter continues to be unresolved. The licensee
representatives stated that effort will be made to define the project
position on this matter,
e.
(Closed) Noncompliance Item (460/80-07-02)
Welding electrical parameters were exceeded for field weld FW-6
of the reactor primary coolant system.
The actions taken by the
welder appeared to have been associated with the fluctuations of the
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electrical output of the welding equipment.
J. A. Jones nonconformance report 1-CNCR-211-141 recommended correction
of electrical system problems, and then "proceding with welds accepting
as-is".
This was rejected by the Engineer, and action taken to assure
that mechanical properties were acceptable, and sensitization of the
stainless steel not questionable. The CNCR supporting documentation
shows that tests were perfonned to ascertain that a maximum heat input
of 79,200 joules per inch may have been achieved by the welder (based
upon ability to control the welding puddle). A test weld was then made
on 12-inch diameter Schedule 80 piping, using an average heat input of
88,300 joules / inch. Mechanical tests affirmed that minimum tensile
properties would have been achieved in the production weld.
Process
control sheet PCS-FWOO6-Repair Revision 1 documents that weld and base
material was excavated on the inside diameter of the weld and safe-end,
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and replacement material welded-in to assure that any potentially
sensitized based material was removed or isolated from process -fluids.
The weld tests, procedures, process control sheet, and dispositioned
nonconformance report were reviewed by the Engineer, an ASME code
inspector, and the NSSS System supplier representative.
Similar action
was also taken for weld FW-7, under CNCR-211-140.
The Engineer and contractor also took action regarding welds being made
on P3 materials, since welding parameters were not properly monitored.
This action involved welding FW-4 and determining the maximum voltage
observed. Thereafter, the weld procedure JAJ-WP-Pl/P3 was requalified at
this maximum value. This was to oe used as a basis for disposition of
related questions on welds FW-1, 5 and 8.
The contractor also established a program (procedure ITI-Oll dated
July 23,1981) to monitor welding parameters for NSSS system welds on a
half-hour basis. The inspector examined records for weld FW-19, which
demonstrated implementation of this. The inspector noted that
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J.A. Jones procedure ITI-011 required monitoring of welding (However, the
in the general services building only on.a weekly basis.
inspector has interviewed some piping welding personnel in the general
services building who stated that quality verification personnel will
monitor their initial welding whenever they set-up in a new area.)
The Bechtel contract coordinator described improvements which has been
made to the electrical equipment, and purchase of fourteen individual
welding machines for NSSS work, to overcome the problem of electrical
fluctuations.
During the past six months on-site, the resident inspector
has not encountered any welder complaints regarding the adequacy of the
equipment, as he had in early 1980. The Bechtel welding engineer stated
that his group's surveillence activities also probed into this area and
had found no current problems. This matter is closed.
f.
(Closed) Unresolved Item (460/80-07-03)
Questionable air-quench practices were employed d'uring test, sample
preparation for qualification of weld procedure JAJ-WP-P3/P3-2A. ' The
specimen was subjected to an air blast to expedite cooling;to. permit
liquid penetrant examination of the backside excavation.
Licensee instructions to J. A. Jones (QA-1/4-80-379 dated October-2,1980)
and the associated J. A. Jones reply (JJUE-80-5204 dated October 16,1980)
indicate that this matter was evaluated and dispositioned. The procedure
in question was voided.
Interview of the responsible J. A. Jones weld
engineer and the ASME inspector on April 7,1982 confirmed that the P3/P3
test sample was discarded and not used as a basis for any weld procedure
qualification. This matter is closed.
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g.
(Closed) Followup Item (460/81-06-01)
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Tool boxes, solvent cans and other foreign material were:found inside
main steam piping, prior to fitup for welding.
The inspector examined weld history records.and detemined that these
each provided a hold point for quality verification of piping cleanliness -
at the time of joint fitup. Various welders and inspectors interviewed
demonstrated concern and knowledge of these cleanliness checks. The.
program appears to adequately provide for assurance that piping interiors
are clean prior to welding and closure. This matter is closed.
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h.
(0 pen) Followup Item (460/81-10-01)
The status of the quality assurance program definition and implementation
was considered an area of significant weakness, including effectiveness
of site surveillance of contractors and manacement involvement.
This matter was described in Appendix A, itein 2, of the NRC letter to
WPPSS dated December 22, 1981, and WPPSS reply letter dated January 22,
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1982).
In IE Inspection Report 50-460/82-03, the inspector acknowledged
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the WPPSS letter, and designated the matter (460/81-10-01) as closed, but
subject to routine future examination.
Paragraph 11.b of this report describes a recent example of WPPSS/Bechtel
lack of involvement in important issues affecting the site contractors.
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This involved lack of cognizance over the details of resignation of the
quality assurance manager of the principal electrical contractor (FWB).
This item is reopened for specific future inquiry when WNP-1 work
resumes.
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(Closed) Followup Item (460/82-02-05)
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The mechanical contractor had introduced ambiguities into the inspection
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requirements of the grouting procedure JAJ-WI-001. As a result, the
basis was unclear for final acceptance of grouting by inspection
personnel.
On March 30, 1982 the contractor issued a new revision 4 to procedure
J AJ-WI-001.
Section 8.1 incorporates specific inspection attributes 'to
be ascertained by the inspectors as a basis for final acceptance. This
item is closed.
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j.
(Closed) Unresolved Item (460/82-05-03) (Reopened as Item 460/82-06-03)
Lack of protection and deteriorating rusting surfaces were observed
in March 1982 on machined faces of flanges of decay heat removal system
isolation valve containment encapsulation vessel DHR-VSL-1A. These con-
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situte local sealing surfaces for the reactor containment building
function.
Bechtel nonconformance report 1-SNCR-24A-02 was initiated January 14,
1982, and shows that these flanges had been imersed during a flooding
incident in January. The BNCR disposition specified washing with clean
water; it was closed and accepted by the Bechtel inspector February 9,
1982. There was no identification of the rusting condition, lack of rust
protection, and deterioration or absence of physical protection
subsequently identified by the NRC inspector.
The vessel manufacturer originally shipped the encapsulation vessels
assembled and sealed with dessicant inside, covered and on skids for
outside storage. The " Vendor Recommendations For On-Site Storage"
(PE-Data WS-1 Rev. 2) recommend maintenance of caps, plugs and dessicant
and resealing of the vessels, and visual inspections of exterior to assure
that the protective covering of the skid is intact and the tanks themselves
are in good condition. The disassembly for installation, and protection
of the sealing surfaces is not specifically recognized in these
instruction.
However, ANSI-N45.2.2 (parts 1.2, 6.5, 6.4.1 and 3.4 together)
requires protection and preservations consistent with orginal packaging
and handling provisions. The Bechtel preventive maintenance quality
control supervisor stated that this was not a matter within his
jurisdiction, in that the encapsulation vessels were issued from storage
to the contractor, and the contractor has responsibility for maintaining
protection during installation work.
In April the inspector observed the deterioration of covers on Class IE
switchgear cabinets at elevation 421 of the general services
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building. Work was in process above the cabinets, and dirt, debris,
metal shavings, nails and similar materials were_ falling on the cabinet
tops. There was no cover on the top ventilation grating of Class IE
13800/480-volt switchaear cabinet 1-APN-USS-0EBl-B, and debris appeared
to have access through that grating. The inspector, an FWB electrician
foreman, and the FWB quality control supervisor examined the interior
and found dirt, metal shavings, and pieces of fine wire'in the vicinity
of terminal blocks. The foreman stated his belief that inspection and-
maintenance of covers and cleanliness were Bechtel responsibility
since Bechtel assumed responsibility for' general preventive maintenance
at the site.
The Bechtel preventive maintenance supervisor stated-that
Bechtel releases the equipment to the field contractor, and performs
the initial wrapping and installation of heaters, from which point
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the maintenance of covers and cleanliness is the contractors'
responsibility. This position appears to be inconsistent with
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Bechtel direction to FWB on January 19, 1962 (. letter BEC-218-82-0014)
which states:
" Preventive maintenance on installed equipment
(Contractor funished) and all Owner-furnished equipment, regardless
of location, will be performed by others." A FWB letter to Bechtel
dated December 28, 1982 (letter 218-BEC-81-2197) demonstrates that
the uncertainties in this area have existed prior to December 1982,
when Bechtel had stopped issuing preventive maintenance cards to
FWB, complicating FWB compliance with their contract comitments for
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preventive maintenance of owner furnished equipment. The control of
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housekeeping and material preservation has been addressed in NRC
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inspection report noncompliance item 80-06-01 (which considered
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repeated housekeeping related inspection findings of NRC Inspection
Reports 79-10, 11, 12, 14 and 80-03); unresolvea item 81-01-01 ;
followup item 81-06-01; and inspection reports which discussed followup
to those items (reports 460/80-04, 80-07, and 81-04). The item
80-06-01 stated "that the measures established to preclude recurrence of
equipment cleanliness and preseveration problems have been ineffective".
The licensee response to the citation described corrective measures
at that time, and NRC inspection report 460/81-04 acknowledged observed
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improvements.
However, since that time, Bechtel has assumed increased
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responsibility as Construction Manager, and organization responsibilities
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have been reassigned and changed.
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In addition to the two specific items addressed above, the NRC
resident inspector had also identified a number of' isolated housekeeping
items to the Bechtel/ contractor staffs during the past four months, which
included:
(1) Uncapped stainless steel piping in the general services
building northwest elevation-395, with a dirty rubber cement grout
bucket in the pipe; 2). two-square-feet by 1/4-inch thick accumulation
of bird-droppings on installed stainless steel piping in.the southwest
pipe tunnel; 3) accumulation of flammable debris at the floor of the
northwest pipe tunnel. These were all corrected by the contractor.
They occurred in the safety related equipment / piping areas of the
general services building.
No particular problems were identified
in the containment building nor main steam isolation structures.
With due regard to the related matters discussed above, the specific
examples of equipment discrepancies (rusting flange . faces and
switchgear protection) appear to be more than just isolated cases,
and represent sufficient current weakness in the housekeeping and
preventive maintenance program to constitute an item of noncompliance.
(460/82-06-03)
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13. Management Meeting
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The inspector met with the licensee quality' assurance manager approximately
weekly to discuss the status of inspection findings. On April 30, the
inspector met with the WPPSS quality assurance and construction organizations.
This joint meeting included the NRC regional office inspectors' presentation
of inspection findings. Personnel who attended this meeting are so noted
(*) in paragraph 1 of this report.
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