ML20093F829

Advises of Inaccuracy in Const Appraisal Team Insp Rept 50-382/84-07 Re Peden Steel.Peden Steel Was Not Subcontractor of American Bridge.Correction of Const Appraisal Team Insp Rept Requested by American Bridge

ML20093F829
Person / Time
Site:	Waterford
Issue date:	07/03/1984
From:	Dobson D LOUISIANA POWER & LIGHT CO.
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
W3B84-0452, W3B84-452, NUDOCS 8407230193
Download: ML20093F829 (7)

Text

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i LOUISIANA P O W E F1 & L 1 G H T! WATERFORD 3 SES + P.O. BOX B + KILLONA. LA 70066

$iuSnYs$vsE July 3, 1984 W3B84-0452 Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

REFERENCE:

Construction Appraisal Team Inspection 50-382/84-07

Dear Mr. DeYoung:

Page VIII-6 of ref erenced report states and Page IV-10 and A-4 imply that Peden Steel was a subcontractor of American Bridge. Based on an NRC finding b that shop welds produced by Peden Steel were deficient a potential enforcement action is listed on page B-2 of referenced report.

Please be advised that Peden Steel was not a subcontractor of American Bridge.

American Bridge has requested that referenced letter be corrected. A copy of their request is attached. Copies of the pertinent pages of the ref erenced letter are also attached.

If there are any questions, please advise.

Very truly yours, Project Manager DED/st Attachments (5) ,

l cc: K. A. Simister, M. Stevenson, R. Watt, R.V. Carus, R.S . Leddick, l T.F. Gerrets, J.T. Collins 8407230193 840703 PDR ADOCK 05000382 PDR G

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i The-inspection also revealed several instances where engineering design disciplines on site did not use the latest drawing and associated design

, changes for engineering and construction activities. Applicable design change documents are not being censistently posted on controlled drawings. The NRC 1 inspectors found deficiencies in the maintenance of the Drawing Close-out

Schedule (the engineering document which identifies outstanding design changes

ondesigndrawings). It also appears that site Document Control has not been using the Drawing Close-out Schedule to audit its files as required by pro-  ;

cedure.

i Corrective Action Systems The NRC CAT review of the applicant's corrective action program revealed several deficiencies, one of which has major significance: The applicant has 4

not initiated adequate and proper corrective action on previously identified violations in five areas. The five areas where this deficiency was found

, involve undocumented loads on seismic supports, pipe supports / restraints not meeting as-built requirements, electrical maintenance procedures for_

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_ motors not being properly performed,(Beficient shoo welds on American Bridge structure () and problems with pipe to structure clearances. ~

s Three other deficiencies of lesser significance were found. Some reported i'

deficient conditions are apparently not being upgraded to nonconformance 4 reports (flCRs) and thus, are not being analyzed for repetitiveness. The .

applicant's quality assurance program allowed some requirements (issuance of hold tags and taking action to preclude repetition) to be removed from quality

• procedures. And thirdly, some required information on nonconformance reports was being omitted.

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j c. Design changes on design drawings and an installation specification ,

were not being identified at the location of work activity. It was l' found that DCNs and FCRs were not being posted against drawings l

'used by Ebasco design disciplines. In addition, it was found that l Document Control was not auditing its files against Ebasco's Drawing Close-out Schedule (Section VII.B.1).

d. Changes to a construction installation specification were reviewed l and approved by an organization different than the organization that perfonned the original review and approval. It was found that FCRs affecting specification MC-1 were reviewed and approved by engineer-ing rather than the construction organization that originally reviewed

andapprovedit(SectionVII.8.2). .

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4. Contrary to 10 CFR 50, Appendix B, Criterion VIII, and LP&L QA Manual

! Section 8, the material traceability and control of some fasteners have i not been adequate to assure the use of correct parts or material (Section VI.B.1).

5. Contrary.to 10 CFR 5,0, Appendix 8, Criterion X, and LP&L QA Manual Section 10, the applicant has not properly executed an inspection program in the s foll.owing areas:

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a. The inspection of Class IE raceway installations relative to the ~

requirements for physical separation, had not been accomplished i in accordance with the' criteria established in the inspection docu-i ments(SectionII.B.1).

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b. The construction inspection.of some masonry walls was not commensurate j' with the assumptions used in the design analysis (Section V.B.6.).

j c. As-built drawings for HVAC seismic restraints do not accurately ,

j reflect the actual installation (Section III.B.3).

! 6. Contrary to 10 CFR 50, Appendix B, Criterion XVI, and LP&L QA Manual Section 16, the applicant has failed to effectively perform the following corrective action activities: ..

1 a. Adequate corrective action has not been taken for Region IV'ideniii-l fied discrepancies regarding the identification and evaluation of

potential pipe to structure clearance problems, addit'fonal loads "

placed on HVAC and electric cable trav uie=ie ="pr~ te, t' enaduct of electrical maintenance, and@efic ent shopwelds in American BridgD structures (Section VIII.B.4) . . .

1 b. Some nonconforming conditions are not being properly documented and l evaluated through the Corrective Action Program (Section VIII.B.2).

7. Contrary to 10 CFR 50, Appendix B, Criterion XVII, and LP&L QA Manual Section 17, some inspection and test records were found to be deficient as

, a portion of the concrete in-process test records for two of the ' concrete i placements sampled were missing (Section V.B.1).

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l The NRC CAT inspectors found a subsequent Notice of Violation issued in NRC Inspection Report 50-382/82-05 against the maintenance of safety-related motors, and further found that l current electrical maintenance procedures are not in all cases being followed. Refer to Section II.8.3.b(1) of this report for a detailed discussion of the NRC CAT-findings regarding electrical maintenance.

i (4) Significant Construction Deficiencies (SCDs) 73 and 78 were issued on April 11, 1983, and April 28, 1983, respectively, to address welding deficiencies by American Bridge in the Reactor Containment Building and the Reactor Auxiliary Building. A comprehensive reinspection program by LP&L was completed and rework has been finished.- ~

he NRC CAT inspect' ors found weld deficiencies in the shop welds fabricated by Peden Steel, which was an American Bridge subcontractor.

I(a detailed discussion of the NRC CAT findings. Refer to Section IV.B.

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L (5) NRC Inspection Report 50-382/83-13 contained a Notice of Violation concerning piping to structure clearance problems i

not being properly identified. LP&L responded to the ,

violation on May 17, 1983, that corrective action was initiat'ed

, to preclude recurrence.

The NRC CAT inspectors found several instances where the t

clearance between piping and adjacent structures did not meet approved Criteria. Refer to Section III.B.1.b of this report for a detailed discussion of the NRC CAT findings.

c. Conclusions .

r The NRC CAT findings in the area of corrective actions indicate that the commitments made to the NRC regarding the recurrence of nonconforming conditions have not been fulfilled. This is a recurring problem and is of considerable concern to the NRC CAT - - '

inspectors.

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<. VIII-6 . -- , 1 l

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' a. Inspection Scope a .

The NRC CAT inspected approximately 120 fee; of welded seam on the refueling pool liner. Twelve welder qualification test records  !

I and 16 welding procedures were reviewed for compliance with the

, applicable codes and specifications. In addition, 30 feet of welded seams involving 40 radiographs were reviewed. Five NDE procedures and five NDE personnel qualification records were also reviewed.

The inspectors also inspected the ends of 28 telltale pipes of both spent fuel pool and refueling pool in ordar tc ascertain that the pools had not leaked during the time they were tested for leakage. The inspection reports associated with these tests were also ruviewed for adequacy of documentation.

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b. Insoection Findings and Conclusions No problems were identified in the areas of inspected welding and NDE activities. Activities were found to comply with the appli-cable construction codes and specifications.  :.

( American Bridg']

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a. Inspection Scope Approximately 380 welds consisting of 80 field and 300 shop fabricated welds were inspected for compliance with the specified acceptance criteria. The shop welds were fabricated by Peden Steel Company. Eighteen welder qualification test records and 15 welding procedures were reviewed for compliance with the appli-cable codes and specifications. In addition, 40 feet of weld

involving 244 radiographs were reviewed. Four NDE procedures were also reviewed for adequacy. -

b. Inspection Findings . .

No concerns were identified in the area of reviewed ""E mivities l and insnactad fiald waldinn ;ay..,wr, curing the inspection o

( stop welds fabricated by Peden steel, the NRC CAT inspectors

! I identified welds which did not meet-the soecified acceptance yriteriaffhree welds were selected for engineering evaiuat on.

mose Diree welds represented the " worst" welds from the inspected i weld sample. Two of the selected welds contained various defects l such as undercut, lack of fusion, crater and were undersized. The l

third weld was a seal weld whereas the drawing required a 1/4-inch fillet weld. Therefore, the required 1/4-inch fillet weld was l missing altogether. As a result of this finding, the applicant l issued DN-SQ-2167. The three welds were evaluated by Ebasco engineering, accepted "as is" and were determined to be adequate

for the intended application.

IV-10

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• June 22, 1984 h9/ NUCLEAA ,- E ff Mr.R._S.Leddickk Senior Vice President Louisiana Power and Light Wate rford III P . O . Bo x "B "

Killona, Louisiana 70066 Re: Nuclear Regulatory Commission Docket 50-382; construction Appraisal Team Inspection 50-382/84-07

Dear Sir:

American Bridge Division, United States Steel Corporation has reviewed the above-referenced report which contains certain allegations regarding deficient shopwelds fabricated by American Bridge's alleged subcontractor, Peden Steel.

As you know, Peden Steel was not American Bridge's subcontractor at Waterford. As fabricator, Peden contracted directly with LP&L and its agent Ebasco. American Bridge had no responsibility whatsoever for Peden's shopwelding activities.

The NRC's report, however, is premised upon the erroneous assumption that Peden was American Bridge's subcontractor. As a result, there is language in the report which suggests that Peden's defective shop-welds were therefore American Bridge's responcibility.

American Bridge considers LP&L responsible for this misunderstanding in that you are required to insure that the NRC has accurate information regarding such matters as the precise contractual relationships of your sub-contractors. We, therefore, demand that you immediately contact the NRC to clarify this situation and modify the May 14 report accordingly, and that such clarification be accomplished prior to any potential enforcement action recommended by the NRC.

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American oss l Bridge 1 o.m . mu t.ssw c mce, .t.=

Mr. R. 5. Leddick June 22, 1984 Page 2 A:r.erican Bridge will continue to hold Louisiana Power and Light fully liable for any damage to our business reputation which we have or may experience as a result of the inaccurate information contained in N C 50-382/E4-07 and all related documentation and activities Yours very truly, fd i L 0 1/ -

chard V. Carus R'C :mb General Manager-Contracting cc: Charles A. Rea,,Esq.

V. Frederic Lyon, Esq.