ML20062H660
| ML20062H660 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/02/1982 |
| From: | Dodds R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20062H653 | List: |
| References | |
| 50-397-82-14, NUDOCS 8208160126 | |
| Download: ML20062H660 (8) | |
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APPEl; DIX A liO11CE OF VIOLATION Washington Public Power Sypply System Docket No. 50-397 P. O. Box 968 Construction Permit
~Richland, Washington 99352 No. CPPR-93 As a result of the inspection conducted during June 1982, and in accordance with the 14RC Enforcement Policy,10 CFR Part 2, Appendix C, 47 FR 9887 (March 9,1952), the following violations were identified:
A.
10 CFR-50 Appendix B, Criterion IX as addressed in Section D.2.5.9 of the WPPSS Quality Assurance Program in Section 17 of the PSAR states in part that, "Hensures shall be established to assure that special processes...are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special re-quireruents. "
ASME boiler and Pressure Vessel Code,Section III, paragraph NC-4223.1 states in part, "...Eending processes shall be selected and quclified to maintain a wall thickness for bent piping sufficient to satisfy the requirements of the design calculations at the resultant thickness..."
Dechtel Power Corporation Procedure SWF/P-P-4 Revision 2, to which the instrument contractor is bound, states in part:
"3.2.1 All pipe bending shall be performed by a bender approved by the PFL.
3.3.1 For austenitic stainless steel each nominal pipe size, weight, heat and radius to be cold bent to a radius more than twenty (20) pipe diameters shall be qualified by a procedure qualification.
3.3.3(h) For stainless steel pipe bent to a radius of more than twenty (20) pipe diameters only, determine the hardness of each section en both the inside and outside radius."
Contrary to the above, between June 1,1982, and June 6,1982, six (6) bends were made in stainless steel pipe in each of the four (4) loops of the hydraulic supply to RRC-V-60 L using an unapproved and un-qualified pipe bender in accordance with an unapproved -and unquali-fled pipe bending procedure.
This is a Severity Level IV violation.
8208160126 820802 PDR ADOCK 05000397 G
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L.
10 CFR 50 Appendix L, Criterion XV as addressed in Section D.2.5.15 of the UPPSS Quality Assurance Program in Section D.0. of the PSAR states "Heasures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations.
Non-conforming items shall be reviewed and accepted, rejected, re-paired or reworked in accordance with documented procedures."
Further, the Ecchtel Quality Assurance Manusl - ASME Section III states in Sections 15.1.1.1 and 15.1.1.2:
ASME Section III items not conforming to their requirements are identified and controlled such that inadvertent use, or installation, is prevented.
The PCQCL is responsible for administering the nonconformance control system.
honconfortaing items discovered during receipt inspection, or construction activities, are touttolled and docun.ented by the use of a honconfuruance Report (Exibit 15A).
The nonconformance report provides for identification and documentation of the non-conformance and control of the item, identifies the authority for approval of proposed resolution, and provides for documenta-tion of reinspection results."
Contrary to the above, safety-related stainless steel piping was being installed in the hydraulic system for the reactor recircula-tion systeiu on June 7-10, 1962.
The piping had been formed by use of an unapproved and unqualified procedure and pipe bender.
A Honconformance Report was not prepared until June 11, 1982, even though the conditions had been identified and reported to the Construction Manager (Ecchtel) by the Authorized Nuclear Inspector on June 3, 1982.
In addition, a Ecchtel Quality Assur-ance Engineer identified the condition on June 6, 1982.
ibis is a Severity Level IV.
Pursuant to the provisions of 10 CFR 2.201, Washington Public Power Supply System is hereby required to subtait to this office within thirty days of the date of this hotice, a written statement or ex-planation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
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_-- 0 Under the authority of Section 182 of the Atoraic Energy Act of 1954, as araended, this response shall be submitted under oath or affirreation.
Consideration raay be given to extending your response tirne for good cause shown.
Aut; 2 1982 dated R. 1. Dodds, Chief Reactor Project Section 2
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14 UNITED STATES f
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j REGION V 1450 MARIA LANE. SUITE 260 0,
g WALNUT CREEK CALIFORMA 94596
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's August 2, 1982 Docket No. 50-397 Washington Public Power Supply System P. O.
Box 968 Richland, Washington 99352 Attention:
Dr. R. G. Matlock Program Director Gentlemen:
Subject:
NRC Inspection This refers to the inspection conducted by Mssrs. A.
D. Toth and R. A. Feil of this office during the period of June 7 - July 9,1982, of activities authorized by NRC Construction Permit No. CPPR-93, and to the discussion of findings held by Mr. Toth and Mr. Feil with Dr. Matlock and other members of your staff at the conclusion of the inspection.
Areas ekamined during this inspection are described in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Based on the results of this inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.
Your response to this notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violation. In your response, also state (1) the measures being taken to effect prompt corrective action (s) once conditions adverse to quality have been identified and (2) how you plan to assure that your contractor (s) implement prompt corrective action (s).
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withold information contained therein within thirty days of the date of this letter.
Such application must be consistent with the requirements of
- 2. 790 (b) (1).
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. Washington Public Power Supply System August 2, 1982
%s Should you have any. questions concerning this inspection, we will be glad to discuss them with you.
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Manage-ment and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, l.\\t vp T. W. Bishop, Chief Reactor Construction Projects Branch
Enclosures:
A. Notice of Violation B. NRC Inspection Report No. 50-397/82-14 cc w/o enclosures:
R.
B. Glasscock, Quality Assurance Director I
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APPENDIX A NOTICE OF VIOLATION ss Washington Public Power Sypply System Docket No. 50-397 P. O. Box 968 Construction Permit Richland, Washington 99352 No. CPPR-93 As a result of the inspection conducted during June 1982, and in accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, 47 FR 9887 (March 9,1982), the following violations were identified:
A.
10 CFR 50 Appendix B, Criterion IX as addressed in Section D.2.5.9 of the WPPSS Quality Assurance Program in Section 17 of the PSAR states in part that, " Measures shall be established to assure that special processes...are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special re-quirements."
ASME Boiler and Pressure Vessel Code,Section III, paragraph NC-4223.1 states in part, "... Bending processes shall be selected and qualified to maintain a wall thickness for bent piping sufficient to satisfy the requirements of the design calculations at the resultant thickness..."
Bechtel Power Corporation Procedure SWP/P-P-4 Revision 2, to which the instrument contractor is bound, states in part:
"3.2.1 All pipe bending shall be performed by a bender approved by the PFE.
3.3.1 For austenitic stainless steel each nominal pipe size, weight, heat and radius to be cold bent to a radius more than twenty -(20) pipe diameters shall be qualified by a procedure qualification.
3.3.3(h) For stainless steel pipe bent to a radius of more than twenty (20) pipe diameters only, determine the hardness of each section on both the inside and outside radius."
Contrary to the above, between June 1,1982, and June 6,1982, six (6) bends were made in stainless steel pipe in each of the four (4) loops of the hydraulic supply to RRC-V-60 B using an unapproved and un-qualified pipe bender in accordance with an unapproved and unquali-fied pipe bending procedure.
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This is a Severity Level IV violation.
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s, B.
10 CFR 50 Appendix B, Criterion XV as a' dressed in Section d
D.2.5.15 of the WPPSS Quality Assurance Program in Section D.O. of the PSAR states." Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations.
Non-conforming items shall be reviewed and accepted, rejected, re-paired or reworked in accordance with documented procedures."
Further, the Bechtel Quality Assurance Manual - ASME Section III states in Sections 15.1.1.1 and 15.1.1.2:
"ASME Section III items not conforming to their requirements are identified and controlled such that inadvertent use, or installation, is prevented.
The PCQCE is responsible for administering the nonconformance control i
system.
Nonconforming items discovered during receipt inspection, or construction activities, are controlled and documented by the use of a Nonconformance Report (Exibit 15A).
The nonconformance report provides for identification and documentation of the non-conformance and control of the item, identifies the authority for approval of proposed resolution, and provides for documenta-tion of reinspection results."
Contrary to the above, safety-related stainless steel piping was being installed in the hydraulic system for the reactor recircula-i tion system on June 7-10, 1982.
The piping had been formed by use of an unapproved and unqualified procedure and pipe bender.
A Nonconformance Report was not prepared until June 11, 1982, even though the conditions had been identified and reported to i
the Construction Manager (Bechtel) by the Authorized Nuclear Inspector on June 3, 1982.
In addition, a Bechtel Quality Assur-ance Engineer identified the condition on June 6, 1982.
This is a Severity Level IV.
Pursuant to the provisions of 10 CFR 2.201, Washington Public Power Supply System is hereby required to submit to this office within t
thirty days of the date of this Notice, a written statement or ex-planation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
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Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Consideration may be given to extending your response time for good cause shown, dated August T., 1982 6
R. T. Dodds, Chief Reactor Project Section 2
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