ML20003F069

Responds to NRC 801024 Ltr Re Violations Noted in IE Insp Repts 50-354/80-14 & 50-355/80-14.Corrective Actions:Record Copy of Requisition Page Assigned to Welder Using Matl & Form Presented for Initials

ML20003F069
Person / Time
Site:	Hope Creek, 05000355
Issue date:	12/02/1980
From:	Martin T Public Service Enterprise Group
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20003F063	List: ML20003F066 ML20003F069
References
NUDOCS 8104200086
Download: ML20003F069 (6)

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December 2, 1980 .

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' lir . Doyce 11. Grier, Director "

U. S. Nuclear llegulatory Cornmission Office of Inupuetton i Enforcement Hegion i  ;.

631 Park Avenue King of Pruusia, Pennsylvania 1940G

Dear if r. Grier:

NRC INSPECTInN REl' ORT 50-354/80-14 AND 50-355/80-14 NO. L AND 2 l' NITS

!! OPE CREEK GENEllATING STATION We have reviewed the report of your inspection conducted on September 2 - October ~), 1980. The report was t ransmitted with yotar let t er o f October 21, 1980 and received on October 30, 1980 The fotLowing corrective actions have been taken or contemplated rela-tive to the one defielency and three infractions determined: ,

l A. " Deficiency applicablo to Docket No. 50-354:

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" 10CFil50, Appendix 0, Criterion V, states, in part, that:

' Act ivi t ies a f fect ing quality shall be prescribed by docu-

• l menred instruettons, procedurer; or drawings. . . sha11 he l accomplished in accordance with these instructions, pro-cedures, or drawings.'

l "Sectton 1G 4.5 of Chapter 16 of the PSAll states, in part, that: '"Bechtel quality rela teil activit ies are documented and controlled by wrttten procedures and instruetions.'

"GEILSE QA 11anual paragraph 11.6.3 states, in part, that:

'The welding supervisor shall be responsible for initiating the Filler !!etal Requisition Section of the JPCS. Welding

' filler metal shall be issued on the basis of this requi-l sittoh The Welding Supervisor shall fill in the l

appropriate Welder Symbol, the material class, type and I s t /.e , and init.Lal the requisition. The issuor shall enter the heat and lot number on the requisition, initial, and date the fore.' .

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" Contrary to the .tbove, review of the JPCS indicated it was not being utill.ced as the working document filler metal requisition form, but rather as a form that a f te r-t he- f ac t recorded that filler metal had been issued."

Reply to A:

1. Correetive steps which have been taken'and the results achieved:

Nonconformity Heport No. 17 was issued by GEI&SE on September 8, 1980. Subsequently, the record copy of the requistrian page of the JpCS was assigned to the welder that would be using the material and the form presented to the individual issuing the electrodes /

f11ler material for inittal.

2. Corrective steps which will be taken to avoid further items of noncompt f ance:

Nonconformity Report No. 17 was dispositioned;

a. Actual requisition page of JPCS will be used for assign-ment to welders as detailed in Section 11.6.3 of GE's QA ifanual. .

b.' ofA training class will be held concerning the issuance electrodes and use of " working copies" of the traveier packages.

3. Date when full ecmpliance will be achieved:

Remobilization by GEILSE is scheduled the first week January 1981, at which time corrective actions required by Nonconformity Report No. 17 will be implemented.

. D. " Infraction applicable to Docket No. 50-354:

"10CFR50, Appendtv. is, Criterion IX states, in part, that:

')feasures shall De established to assure that special pro-cesses, including welding... are controlled and accomplished...

using qua1ified procedures in accordance with appitcable codes, standards specifications, criteria, and other special F requtrements.'

"Section 16.2.0 of Chapt er 16 of the PSAR states, in part, that: 'The NSSS Contractor and Architect-Engineer shall establish controls over special processes such as welding. . e These controls shall assure that the procedures... are duly .

l qualified in accordance with applicable codes, standards...'

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o i Hopee kl. Grier 12/2/80 "Sectton 10.2. I of t he GEILSE QA if anual states , in part, that: 'The Traveler. . . speel fles the procedures or instruct ions with revision, to be followed for critical operations nnd Code examinations and tests...'

" Contrary to the above, as of Augustbrackets 21, 1980, were thebeing control rod drive mechanism housing support welded to the reactor vessel pedestal liner without prior establishment of a code basis for installation and inspectlon."

Reply to 11:

1. Corrective steps which have been taken and the re-

' suits achieved;

a. gel &SE issued SDDII, Supplier Deviation Disposition Request, No. 16 (Bechtel No. 11008 No. 12), regarding CRD beam seats installed using a welding procedure

.j that did not meet the requirements of the AWS Code prequalifications. (Dihedral Angle of Skewed "T" Joints, Section 2 - Design Welded Joints.)

Field Deviation Disposition

b. GE/NEEG in turn issued FDDR, Request, No. KT1-042. Subsequent disposition was as I, follows:

installation of the equipment using Section IX qualifications is acceptable, provided a mock-up is conducted. The mock-up shall luplicate the smallest skewed angle joint. The lack of filler metal penetration into the root shall be recorded from the thickness

mock-up and the value added to the throat It shall be of skewed angle production welds.

veri fied that welds covered by the c.ock-up are

- adequate.

c. Bechtel concurrence in the use of FDDR KT1-042 as disposition to SDDR NCR-12 has been obtained.

further 2.

Cortective steps which will be taken to avoid items of noncompliance:

GE/NERG review of design of similar areas revealed no other weld configurations that will require special con-siderat ions other than those addressed by FDDR KT1-042.

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3.

The date when full compliance will be achieved:

gel &SE is scheduled to 'remobilize in January.1981, at which time the dispositton (mock-up) of,FDDR~042 wiIL cGITE.e 11C e . *

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Doyce 11. Grier 12/2/80 C. " Infraction applicable to Docket No. 50-354:

• 110CFR50, appendix 0 Criterion IX states, in part, that:

' Measures shall be established to assure that special pro-cesses, including welding... are controlled...'

"Section 16.2.0 of Chapter 16 of pSAR states, ist part, that:

'The... Architect Engineer shall estrblish controls over special processes such as welding...'

" Contrary to the above, as of September 18, 1980, controls were not established over welding preheat operations which resulted in damage to safety related concrete adjacent to areas being prehoated."

Reply to C:

1. Corrective steps which have been taken and the results achieved:

a. Preliminary inspection of the af fected areas by Bechtel Civil Engineers indicates the concrete experienced only superficial damage. A full inspection will be performed and documented af ter removal of paint from the concreto. Hemo. val of the paint is scheduled for completion by January 15, 1981.

b. Craft wel'ders have been instructed in correct pre-heating procedures and the item is included in the Weekly Indoctrination Training Class for new welders.

c. Field Engineering and C# have been instructed to be aware of preheating operations and to take appropriate acttons when preheating operations are not being accceptished satisfactority.

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2. Correct tve steps which will be taken to avoid further items of noncompliance:

Same as corrective steps taken.

3. Date when full compliance will be achieved:

All weld preheating operations are in full compliance with appitcable codes and standards.

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D. " Infraction applicable to Docket Nos. 50-354 and 50-355:

"10CFR50, Appendix 0, Criterion V states, ic part, that:

' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accompitshed in accordance with these instructions, procedures, or drawings.'

"Section 16.4.5 of Chapter 16 of the PSAP states, in part, that: 'Bechtel quality related activities are documented and controlled by written procedures and instructions.'

in paragraph 8 that "Dechtel there areSpecification C-12G(Q) three acceptable boltstatestightening methods permitted for erection of structural steel. .

" Contrary to the above, as of September 24, 1980, ironworkers were not tensioning bolts in accordance with specification C-120(Q) requirements. Additionally, there was a misunder-standing amongst site QC personnel as to the acceptable methods of bott tensioning."

Reply to D:

1. Cortective steps which have been taken and the resitIts achieved: , ,

Bechtel QC initiated NCR 006 for project review / dis-position. To assist in the response to the NCR, QC has inspected approximately 14% or 900 accessible bolts installed *xithout load-indicating washers using a cattbrated torque wrench. Approximately 2T or 18 bolts tested had not been property torqued.

2. Corrective steps which will be taken to avoid furtner items of noncompliance :

Personnel involved have been advised that all future connections will be installedThe withoption load-indicating of washers calibrated o f turn-o f-the-nut method. will impact wrench will remain in the specification but be used as a last resort only and in strict compliance with the specification and AISC requirements.

3. 11 ate when full compliance will be achieved:

Based on data obtained through examination and review of the specification and design requirement, Project Engineering ts scheduled to disposition Noncon formance 1981.

Report M. 000 on or before January 30, .

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G- 12/2/80 If you require additional information, we will be pleased to discuss it with yois.

Very truly yours, g-CC Office of Inspectfon & Enforcement Div of fle.tetor Construction & Inspection Washington, EC

11. E . Storris Bechtal Power Corp.

San Frarieiseo. CA e

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