GO2-83-108, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-14.Corrective Actions:Sampling Plan Developed to Provide 95% Confidence Level That Less than 5% Defects Exist in Sample Lot

Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-14.Corrective Actions:Sampling Plan Developed to Provide 95% Confidence Level That Less than 5% Defects Exist in Sample Lot

ML20083F666
Person / Time
Site:	Columbia
Issue date:	11/21/1983
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20083F665	List: GO2-83-108, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-14.Corrective Actions:Sampling Plan Developed to Provide 95% Confidence Level That Less than 5% Defects Exist in Sample Lot
References
GO2-83-1080, NUDOCS 8401030254
Download: ML20083F666 (6)

Text

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. RECEIVED Nr~o Washington Public Power Supply System P.O. Box 968 2000GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 1J33 i:0 V 2 5 /.M 11. I 7 November 21, 1983 t

G02-83-1080 1\EGlon y:s -

Mr. J. B. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

Subject:

NUCLEAR PROJECT N0. 2 NRC INSPECTION REPORT 83 NOTICE OF VIOLATION - ITEM C

References:

1. Letter D.M. Sternberg to C.S. Carlisle, dated June 3,1983

2. G02-83-592, dated July 1, 1983, C.S. Carlisle to D.M.

Sternberg

3. G02-83-678, dated July 29, 1983, C.S. Carlisle to D.M.

Sternberg The Washington Public Power Supply System hereby provides a final response to the Notice of Violation (Item C) transmitted as Appendix A via the reference (1) letter.

Attachment I will fully answer NRC concerns related to the Quality Class shown on Project Engineering Directives (PED's).

If you have any questions, contact Roger Johnson, WNP-2 Project QA Manager, at(509)377-2501, extension 2712.

lk G.C. Sorensen

.. smJ Manager, Regulatory Programs GLB/jdb Attachments: 1. Final Response

2. PED List cc: W.S. Chin, BPA N.D. Lewis, EFSEC A. Toth, NRC Resident Inspector Document Control Desk. NRC 8401030254 831221 PDR ADOCK 05000397 G PDR

.y - . - - .

Attachment I WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO. 2 DOCKET N0. 50-397 LICENSE NO. CPPR-93 FINAL RESPONSE TO INSPECTION REPORT 83-14 The Supply System provides the following final response to Item C of Appendix A " Notice of Violation." For clarity, the violation is repeated followed by the appropriate response.

Notice of Violation Criterion III of 10CFR50, Appendix B states, in part, that design control measures "shall include provisions to assure that appropriate quality stan-dards are specified and included in design documents and that deviations from such standards are controlled." FSAR drawing M539 and Table 3.2.1 identify the piping and associated components of the floor drain system, upstream of primary containment isolation valve FDR-V-4, as Quality Class I. This invoked appropriate quality standards and related quality control inspections.

Contrary to t'.e above, on November 11, 1982 Burns and Roe issued design change PED-215-H-G046, which improperly downgraded the quality class of (at least) pipe supports FDR-900N, 90lN, 902N, and 903N from Quality Class I to Quality Class II. The design change itself appeared to be improperly classified as Quality Class II. The improper downgrading was not identified by the signa-tory reviewers of the design change. The installation of (at least) pipe support FDR-900N did not receive independent inspection by quality control personnel, nor was it included in the as-built program for final engineering verification.

This is a severity level IV violation (Supplement II).

Supply System Amended Response Letter G02-83-592, C.S. Carlisle to D.M. Sternberg, dated July 1, 1983 provided our interim response in regards to corrective action taken/results achieved and action taken to prevent recurrence. The following information is provided as supplemental information to update action taken to preclude recurrence.

To ensure that the above described condition does not exist in Project Engi-neering Directives (PED's) issued by other disciplines of the A/E, the Project has developed a sampling plan by which a 95% confidence level can be estab-lished that this condition does not exist in other disciplines.

The sampling plan to provide a 95% confidence level that less than 5% defects exist in the sample lot is as follows:

Samplc Selection A computer listing of all PED's issued (approximately 29,000) has been generated, and all PED's assigned a sequential number of 1 through 29,000.

Then, a random computer listing of numbers was generated. Utilizing the list of random numbers, select the PED assigned the sequence number which corresponds to the random number. This selection was broken down into a sample size for Quality Class I (QCI) and Quality Class II (QCII)

PED's.

Attachment I Page 2 of 4 o Quality Class I PED's were reviewed to assure the appropriate review /

check had been performed prior to being approved and issued.

e Quality Class II PED's were reviewed to assure that they had been assigned the correct Quality Class.

Corrective Action Sixty (60) Quality Class I PED's were randomly selected and re-evaluated by suitably qualified engineers, who had no prior involvement with the PED's, to determine if the PED's were technically adequate and if they received a review prior to issuance. All 60 PED's were determined to be technically adequate and that the Group Supervisor signature, does, in fact, constitute the " review approval" as prescribed by WNP-2-017. No further sampling was deemed necessary.

Sixty (60) Quality Class II PED's were randomly selected and the applicable baseline drawing reviewed to verify that the proper quality classification was specified. From the initial sample of (60) Quality Class II PED's, four (4) Electrical PED's were identified as being improperly classified.

The four (4) PED's are all associated with non-essential and non-safety re-lated cable and specify cable / conduit routing and cable terminations.

Electrical Drawings referenced in the PED's require that the non-safety related, non-essential, conduit installation or cable termination be performed in accordance with Quality Class I work procedures. Therefore, as prescribed by WNP-2-017, the PED's should have been classified Quality Class I and II, not

,just II.

As a result of the four (4) observations in the initial sample, it was deemed appropriate to pursue the matter further. Although it could be argued that the above noted observations do not constitute failures since they have been confirmed as being non-safety related and having no impact on actual installation, it was decided to take a more conservative approach and expand the sample.

Three hundred and eleven (311) Quality Class II PED's were reviewed.

A total of twenty (20) PED's, eighteen (18) Electrical and two (2) Civil, were determined to have the improper quality class designation en the PED lead sheet. These PED's are listed on Attachment II.

Thirteen (13) out of fourteen (14) Electrical PED's observed in the expanded sample exhibited the same characteristics as did the four (4) in the initial sample of sixty (60); i.e. , non-essential, non-safety related cables requiring installation or termination in accordance with Quality Class I work procedures.

The PED's also should have been classified as Quality Class I and II on the PED lead sheets. The other one (1) Electrical PED was issued for a " drawing change only", but related to Quality Class I safety-related cable and, therefore, the PED lead sheet should have specified Quality Class I.

,. _ . . . . . . - . . . . , , . _ _ _ _ - - . . . . m, ._ - --. . -

Attachaent I Page 3 of 4 One (1) of the two (2) Civil PED's is related to work on a non-essential, non-safety related coaponent (ladder). However, as in all but one (1) of the Electrical PED observations noted above, the applicable baseline drawing requires that installation be accomplished in accordance with Quality Class I work procedures. The other Civil PED is for core drilling in a Quality Class I structure. This core drilling is required by the applicable baseline drawing to be accouplished in accordance with Quality Class I work procedures.

Therefore, the PED lead sheet should have specified Quality Class I.

In each of the Electrical and Civil observations identified above, the PED technical direction did not revise any of the applicable requirements pertain-ing to qutlity. -Therefora, since tho PED r.u:;t be utili;ad in ccnjunction with the applicable drawings it modifies, there was no impact on construction quality.

l In sumraary, of the twenty (20) Quality Class II PED's that had the quality class iaproperly identified on the PED lead sheet, eighteen (18) were asso-ciated with non-essential, non-safety related (QC-II) components that are routed, terminated or installed in designated Quality Class I areas. Further, the applicable baseline drawings referenced in the PED's specify what portion of the work raust be accomplished in accordance with Quality Class I or Quality Class II work procedures. Since these PED's did not revise any of the quality requirements specified on the applicable drawings, they had no impact on the specified construction quality requireraents. The remaining two (2) PED's were associated with Quality Class I components or structures. One (1) PED was associated with " drawing change only" to reflect actual cable routing which was previously approved by Engineering. The other PED was associated with core drilling in a class I structure in the Make-Up Water Pump house.

The core drilling was required to be performed in accordance with Class I work procedures as prescribed by the baseline drawing referenced in the PED.

Having identified these twenty (20) Quality Class II PED's that were improperly t

classified per the requirements of UNP-2-017, the Supply System cannot rigor-

ously comply with the 95% confidence criteria that less than 5% of the Quality Class II PED's were iraproperly classified with respect to quality class, as

, originally intended. However, based upon the results of the PED evaluation program, suixaarized above, which indicates that there was no impact on the specified construction requirements, the Supply System: (1) does not believe that a significant problera warranting further investigation exists; (2) be-lieves that design control has been raaintained; and (3) believes that the i problem identified with regard to the iraproper downgrading of some Quality Class I supports was an isolated occurrence.

t The following PED's have been issued to reclassify the supports inproperly

downgraded

215-H-N178, 215-H-N182, 215-;i-N390, 215-H-N510, 215-H-N504, 215-H-N962, 215-H-i;971, 215-H-P742.

Attachment I Page 4 of 4 Action Taken to Prevent Recurrence A letter to all engineers has been issued identifying the problem regarding the improper quality classification identified on PED's and directs them to take the necessary action to eliminate these administrative errors and assure full com-pliance to the PED procedure, WNP-2-017.

. -o ATTACHMENT II PED'S IMPROPERLY CLASSIFIED AS QUALITY CLASS II

1. 216-E-0223 2.

218-E-0572

3. 218-E-1329 X

4. 218-E-2160 X

5. 218-E-2165

6. 218-E-2250

7. 218-E-2821

8. 218-E-3127

9. 218-CS-3610

10. 218-E-3620

11. W218-E-3682

12. 218-E-4422

13. 218-E-5107

14. W218-E-5135 X

15. 218-E-A103 i 16. 218-E-Al27

17. 218-E-A360

18. 218-E-A781

19. 218-E-A902 X

20. 215-CS-Pl78 X = Identified on Original Sample of Sixty (60) l l

t