ML20054N040

Responds to NRC Re Violations Noted in IE Insp Rept 50-508/82-04.Corrective Actions:Chicago Bridge & Iron Reviewed Scope of Containment Vessel & Provided List of All Structures Installed Per Classification D

ML20054N040
Person / Time
Site:	Satsop
Issue date:	05/21/1982
From:	Leddick R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20054N036	List: IR 05000508/1982004 ML20054N040
References
GO3-82-524, NUDOCS 8207150294
Download: ML20054N040 (9)

Text

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. j yJ A Qwnia Washington Public Power Supply System;#, ,, ..

Box 1223 Elma, Washington 98541 (206)482-4428

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Docket Number 50-508 -.

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, May 21, 1982 G03-82-524 U. S. Nuclear Regulatory Commission, Region V Office of Inspection and Enforcement 1450 Maria Lane, Suite 260 Walnut Creek, California 94596-5368 Attention: Mr. T. W. Bishop Acting Chief, Reactor Construction Projects Branch j

Subject:

NRC INSPECTION AT WNP-3 IE REPORT NO. 50-508/82-04 NONCOMPLIANCES (50-508/82-04/01) AND (50-508/82-04/02)

Reference:

NRC Letter, NRC Inspection at Washington Nuclear Project No. 3 (WNP-3), dated April 13, 1982, Mr. T. W. Bishop to Mr. R. S. Leddick.

The referenced letter identified two 10CFR50, Appendix B, violations found as a result of the NRC Inspections, conducted on March 1-5 and 15-19, 1982, of activities authorized by NRC Construction Permit No.

CPPR-154. Violation A (Noncompliance 50-508/82-04/01) cited a failure to fabricate and install equipment (CB&I Containment Dome Inspection Platform and Ladders) in accordance with the specified quality program.

Violation B (Noncompliance 50-508/82-04/02) cited a failure to control design change documents in accordance with procedure requirements.

The Supply System was directed to provide a response to the Notice of Violation and, with respect to Violation A, include whether other struc-tures have also been incorrectly fabricated and installed by the same

Contractor to the Quality Classification "D" rather than Quality Class I.

Attached is a report detailing corrective / preventive actions taken for the two subject noncompliances. The Supply System considers Violation

B (Noncompliance 50-508/82-04/02) to be satisfactorily resolved. Vio-lation A (Noncompliance 50-508/82-04/01), however, cannot be resolved

at this time because, as noted in the attached report, the detailed analysis and investigation required to determine the scope of the prob-lem and resultant corrective actions has not been completed. A report of the final corrective / preventive action and date of full compliance for Violation A will be forwarded to youc office by July 30, 1982.

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8207150294 820708 PDR Q

ADOCK 05000500 PDR

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Mr. T. W. Bishop Page 2 May 21, 1982 G03-82-524 Should you have any questions or desire further information, please contact me directly.

S. Leddick, 760 Program Director, WNP-3 DRC/tt Attachment cc: J. Adams - NESCO D. Smithpeter - BPA Ebasco - New York WNP-3/5 Files - Richland

)

R. S. LEDDICK, Being first duly sworn, deposes and says: That he is the Program Director, WNP-3/5, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that 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 3 [ Of ,1982.

R. S. LEDDICK 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 d l day of 'Wlhty , 1982.

o(6J2h (6 NotaryPublicinandfortheState of Washington Residing at ELMA

. Attachment to G03-82-524

' May 21, 1982 Violation A (Noncompliance 50-508/82-04/01 10CFR50, Appendix B, Criterion 11 states that: "The quality assurance pro-grams 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 Quality Assurance Program documented in approved PSAR Deviation No. 26-WP, states, in part, that: "The Supply System re-quires its Quality Class I contractors...to establish and implement Qual-ity Assurance Programs consistent with the applicable criteria of 10CFR50, Appendix B."

WPPSS 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 10CFR50, Appendix B.

Ebasco Specification No. 3240-213 entitled " Steel Containment Vessel" is classified as a WPPSS Quality Class I specification. Paragraph 1.1 of this specification states, in part, that: "The Containment Vessel in-cludes. . . 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 dome inspection walkway and handrail to be sup-plied by the 213 contractor.

Contrary to the above, on March 5, 1982 the inspector observed undersized welds, excessive undercut, and partial penetration welds in lieu of the required full penetration welds on installed and painted portions of the Unit No. 3 dome 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 Classifi-cation "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 that 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 10CFR50, Appendix B requirements.

Corrective Actions Taken Two preliminary corrective action steps are being accomplished as follows:

, 1. Chicago Bridge & Iron has reviewed the entire scope of the containment l vessel and has provided Ebasco with a list of all structures (e.g.,

l ladders, catwalks and other appurtenances) installed in accordance with CB&I's Classification D. Ebasco is presently reviewing and verifying this listing.

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Attachment to G03-82-526 Page 2

'May 21, 1982 Corrective Actions Taken (Continued)

2. Ebasco has identified to CB&I all Class D structures in the contain-ment vesse! that require seismic analysis and design. CB&I is presently performing a seismic analysis for these items and will submit the anal-ysis to Ebasco for review and verification.

Upon completion of the above actions and verification of as-built conditions, a comprehensive plan will be developed to correct all deficiencies, includ-ing those identified by the NRC Inspector.

In conjunction with the above, Ebasco is reviewing the program for contract review and approval to determine the cause of the incorrect quality classifi-cations.

Actions Taken to Prevent Recurrence and Date of Full Compliance Actions taken to prevent further items of noncompliance will be identified and implemented based upon the results of the investigations outlined in the corrective action steps above. A complete report of these actions, in-cluding a date of full compliance, will be provided to your office by July 30, 1982.

Violation B (Noncompliance 50-508/82-04/02) 10CFR50, Appendix B, Criterion V, states, in 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-WP, states, in part, that " Contractors and vendors, including Ebasco...are required to have written... procedures...which govern their quality related activities...."

Ebasco Procedure No. PSP-RE-2-36, Rev. 1," Initiation and Processing of Project Change Proposals" includes the following requirements for the issuance and control of quick fix project change proposals (QFPCP):

i j e Paragraph 3.3.2.3 " Originator-Completes section 1 through 19 as j appropriate on the QFPCP form." Section 2 of the l QFPCP form requires affected drawings and speci-j fications to be listed.

l e Paragraph 3.3.1.1 "The proposal must address specific changes to t design drawings...."

I l e Paragraph 3.3.2.7 " Resident Engineer / Discipline-Assures adequacy I

of technical direction and that all contracts af-fected by the technical direction are identified on the QFPCP."

i s

. Attachment to G03-82-524 Page 3

'May 21, 1982 Violation B (Noncompliance 50-508/82-04/02) (Continued) e Paragraph 3.3.1.10 "For voiding of Design Change QFPCPs, see para-graph 3.2.8."

e Paragraph 3.2.8(a) "If an approval S-TP or QFPCP is not to be replaced, the modification shall be voided by the issuance of a DSCN in accordance with Reference 4.3."

e Paragraph 3.2.8(b) - If the technical information on S-TP or QFPCP re-quires revision, a superseding document modifica-tion may be prepared which indicates the voided document modification number in the appropriate block of the form. Supersession shall not be par-tial but shall void the superseded document in its entirety."

Contrary to the above, the following procedural noncompliances were iden-tified on March 18, 1982:

e Quick fix project change proposal (QFPCP) No. 35Q-06681, dated February 24,1982,was issued without listing Ebasco drawing No. G-3510 SH 3, Rev. 4 as an affected design drawing.

e QFPCP No. 35Q-06723, dated February 25, 1982,was issued without listing Chicago Bridge and Iron drawings nos. 3272-409, SH 1, Rev. 4 (Ebasco No.

3240-37090, Rev. 1) and 3272-409 SH 2, Rev. 4 (Ebasco No. 3240-37091, Rev. 1) as affected drawings.

e QFPCP No. 35Q-06723 did not identify the section detail affected by the design modification.

e QFPCP No. 35Q-06723 did not identify that contract no. 3240-113 was affected by the design modification.

e QFPCP No. 35Q-06681 was cancelled on February 26, 1982 and superseded by QFPCP No. 35Q-06723. A DSCN was not issued to void QFPCP No. 35Q-06681 l nor did QFPCP No. 35Q-06723 indicate that it superseded QFPCP No. 35Q-06681.

As a result of these procedural noncompliances, the construction contractor's controlled drawing file contained the cancelled QFPCP No. 35Q-06681 posted

( as a modification to the applicable Chicago Bridge and Iron detail drawing.

l The design modification contained in QFPCP No. 35Q-06723 was being imple-

! mented although not posted as a modification to the applicable Chicago Bridge l and Iron detail drawing.

i Background for Violation B l

QFPCP-35Q-06681 was issued as an " Instant" QFPCP to clarify weld requirements detailed on Chicago Bridge & Iron drawings. Due to an improper erection se-quence used by the installing contractor, the weld requirements (prequalified l weld joint configuration TC-U4b) specified by QFPCP-35Q-06681 could not be l followed without extensive rework. To preclude delays in construction as a i

Attachment to G03-82-524 Page 4

. May 21, 1982 Background for Violation B (Continued) result of qualifying a new weld joint, QFPCP-35Q-06681 was cancelled prior to controlled distribution. QFPCP-35Q-06723 was then initiated, as an

" Instant" QFPCP against the Ebasco design drawing (3240-G-3510), to author-ize an acceptable alternate beam connection that would allow the contractor to continue construction in accordance with prequalified weld joint con-figuration TC-U4d or TC-U4b.

Corrective Actions Taken The following responses are applicable to the procedural noncompliances identified by the NRC Inspector:

e QFPCP 35Q-06681 did not list Ebasco drawing, G-3510 SH 3, Rev. 4, as an affected design drawing.

Response: Section 2 of the QFPCP form is intended to list drawings 1 that the QFPCP changes and is posted against. QFPCP 35Q-06681 did not affect or change the Ebasco drawing. QFPCP 35Q-06681 was issued to identify an acceptable prequalified weld joint configuration. It should be noted that Ebasco design drawings are " general," providing load data and minimum requirements for joint design. CB&I is required to design and detail connections in accordance with the design criteria specified on the Ebasco drawing. In this instance, the design criteria on the Ebasco drawing was not changed; therefore, the drawings were not required to be listed on the QFPCP.

o QFPCP 35Q-06723 did not list the CB&I drawings as affected drawings.

Response: QFPCP 35Q-06723 did not change the CB&I drawings. It was issued only to provide an acceptable alternate beam connection that would allow the contractor to continue construction in accordance with a prequalified weld joint configuration. The same explanation noted in the response to the first procedural noncompliance above is also applicable to this item.

e QFPCP 35Q-06723 did not identify the section detail affected by the design modification.

I T. sponse: The section detail was not identified on QFPCP 35Q-06723 because it was not affected or changed by the QFPCP. As previously noted, only an alternate method, that did not change the section de-tail, was provided.

e QFPCP 35Q-06723 did not identify Contract 3240-113 as affected by the i design modification.

Response: Due to the reasons previously stated above, Contract 3240-113

, was not affected. Consequently, it was not identified on QFPCP 35Q-06723.

e A DSCN was not issued to void QFPCP 35Q-06681 nor did QFPCP 35Q-06723 indicate that it superseded QFPCP 35Q-06681.

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. Attachment to G03-82-524 Page 5

' 'May 21 o 1982 Corrective Actions Taken (Continued)

Response: A DSCN was not issued to void QFPCP 35Q-06681 because pro-cedures did not address voiding a QFPCP by DSCN prior to issuing for controlled distribution.

QFPCP 35Q-06723 did not indicate that it superseded QFPCP 35Q-06681 because the PCP system did not recognize the existence of QFPCP 35Q-06681.

Since QFPCP 35Q-06681 was voided prior to controlled distribution, it was considered nonexistent.

, Both items above are considered weaknesses in the PCP system and re-quire procedure changes to resolve the conditions. These actions are addressed, under " actions taken to prevent recurrence," in this report.

The following corrective actions were taken as a result of the problems identified by the NRC Inspector:

The Contractor (JA Jones, 3240-265) was notified by speed letter and ver-bally that QFPCP 35Q-06723 superseded QFPCP 35Q-06681.

A review of all QFPCPs that were issued as " Instant" and subsequently

, voided, prior to distribution by Ebasco Document Control, is currently in progress. Upon completion of this review, any QFPCP that was issued as an " Instant" and voided (cancelled) prior to distribution by Ebasco Document Control will be evaluated to determine if the Contractor was informed and the action documented. Ebasco Resident Engineering will inform the contractor in those instances when documentation cannot be located. This review and possible written notification to the contrac-

! tor will be complete by May 24, 1982.

Actions Taken to Prevent Recurrence To preclude recurrence of the last procedural noncompliance identified above, REI-14 (Resident Engineering Controlled Issuance of QFPCPs) will be amended. Specifically, it will be revised as follows:

"Upon Instant PCP status. change (i.e. cancelled, revised, voided),

the Resident Engineer Discipline or his designee will send the suggested standard memo (see attachment) or equivalent notifying copyholder that the status of the Instant is changed and address resulting impact i

to hardware and software. A copy of this memo, along with copy of

PCP will be sent to the design change clerk."

Paragraph 3.3.1.2c of PSP-RE-2-36 refers to REI-14 for details on the con-trol of Instant QFPCPs. Paragraph 3.3.1.2e2 also addresses Instant QFPCPs (cancellation prior to ESSE evaluation); however, it does not refer to REI-14 for guidance. This will be corrected by Revision 2 of PSP-RE-2-36.

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e Attachment to G03-82-524 Page 6 May 21, 1982 Actions Taken to Prevent Recurrence (Continued)

Training will be scheduled for all affected Resident Engineering personnel to assure they are aware of and understand the method to be used in voiding a QFPCP of this nature.

Date of Full Compliance The date of full compliance is June 30, 1982.

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