GO2-83-592, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-14.Corrective Actions:Review of Nonconformance Repts Identifying Locations of Honeycombs or Voids Repaired by Contract 6426 Will Be Conducted

Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-14.Corrective Actions:Review of Nonconformance Repts Identifying Locations of Honeycombs or Voids Repaired by Contract 6426 Will Be Conducted

ML20082B788
Person / Time
Site:	Columbia
Issue date:	07/01/1983
From:	Carlisle C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GO2-83-592, NUDOCS 8311210329
Download: ML20082B788 (8)

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Washington Public Power Supply System pp P.O. Box 968 3000GeorgeWashingtonWay Richland, Washington 99352 (509)82-5p Docket No. 50-397 N S gg July 1, 1983 O/0,'/tqp G02-83-592 e Mr. D. M. Sternberg Chief, Reactor Projects Branch 1 U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

Subject:

NUCLEAR PROJECT N0. 2 NRC INSPECTION REPORT 83-14, NOTICE OF VIOLATION

Reference:

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

The Washington Public Power Supply System hereby provides a reply to the Notice of Violation transmitted as Appendix A via the Reference letter. Our reply pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice" Part 2 Title 10. Code of Federal Regulations, consists of this letter and Attachment 1, which contains our response to the Notice of Violation.

If you have any questions or desire further information, please contact Roger Johnson at (509) 377-2501, extension 2712.

Program Director, WNP-2 RTJ/kd

Attachment:

As stated cc: W.S. Chin, BPA N.D. Lewis, EFSEC Document Control Desk, NRC l

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8311210329 830701 PDR ADOCK 05000397 i l 0 -__PDR g _

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. Attachment 1 .

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Supply System Nuclear Project No. 2 l Docket No. 50-397 License-No. CPPR-93 Response to Inspection Report 83-14 Notice of Violation The Supply System response to each item of Appendix A " Notice of Violation" is included in this attachment. For' clarity, each item violation is repeated and foll sed by our response. Specific aspects of items A and C, as requested by the transmittal letter, are addressed within the response.

A. Criterion IX of 10CFR50 Appendix B states, in part, that "iieasures shall be este.blished to. assure that special processes...are controlled and accom-plished...in accordance with applicable codes, standards, specifications, criteria, and other special requirements." . The FSAR section 3.8.4.2'identi-fies that ACI-301-66, ACI-318-63, and ANSI-45.2.5-74 have~been adopted, to the extent applicable, in.the design and construction of Seismic Category I structures.

1. Part 7.14 of ACI-318 requires that minimum concrete protective covering for principal reinforcement, ties, stirrups or spirals in beams shall be 1-1/2 inches.

2. Part 5.1.1 of ACI-318 requires that before concrete.is placed all debris shall be removed from the spaces to be occupied by the concrete. Part :

4.4 of ANSI-H45.1.5 requires-inspection of formwork for cleanliness.-

3. Part 4.6 of ANSI-i146.2.5 requires that=any indications _of. voids or con ' .

tamination shall. be explored, by physical removal. of concrete,11f neces-sary, to determine the extent of,such voids or contamination and that -

appropriate repairs shall.be made..

Concrete placement and grouting procedures CP-1 and CP-3 both require clean -

liness of. forms prior to placement.- _

Contrary to the nbove, on April 13, 1983 conditions existed Ohich indicated that measures were inadequate to assure concrete . repairs or piacement.in; accordance with applicable codes:

ilarch 17, 1983, the civil contractor (Peter Kiewit Sons'gCo.)[ repaired con-- -

-crete beam No. 283 of a reactor building. floor slab (room R-ll2),resulting;

- in a completed and accepted concrete repair with visualcevidence of contam-tination in or adjacent to the repair and without exploration to determine; extent. The contamination demonstrated inadequate removal:af; debris prior _

to concrete placement'or repair.

~ On an unidentified date - an . unidentified. contractor 1had completed a repair :

to beam.No. 2B11.of;a. reactor building floor s1ab. elevation 470:(coordinates K-8.5)'resulting in a patch w'th~ multiple cracks,31ack of bond to priore

. concrete,=and with reinforcing. steel coveriof less'than 1/4: inch.; ,

.Thisfisasev'erityt level IV' violation-(Supplement:II).. = -

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' Page 2 of 7 SUPPLY SYSTEM RESPONSE:

Corrective Action Taken/Results Achieved

} In response to the findings related to beam 2B3 (visual contamination con- '

sisting of a cigarette butt and a small piece of wood embedded at the con-crete beam surface) and beam 2B11 (multiple cracks, lack of bond to prior concrete and reinforcing steel cover less than 1/4-inch) the following has

! occurred. The Architect / Engineer (A/E) has commenced an investigation by

directing the removal of the patch area on beam 2811 and exploratory chipp-ing of beam 283. Exploratory chipping of a patch on beam 2B25 with similar conditions was also performed. Findings to date are

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o The grout used for patching the original rock pocket for beams 2811 and 2825 was found to be poorly consolidated. Grout in the 283 patch area was found to be poorly consolidated in areas.

e' The chipping exposed the bottom layer of. reinforcing steel for all three

, beams and for all three beams, the ACI code minimum clearance require-ments were not met in the areas of lap splice resulting in congested.

reinforcing steel in this area. This violation led to. rock' pockets,

,. the extent of which or effect on beam adequacy has not been determined

at this time.

a e On beam 2811, only 7 lap splice dowels of the 8 required were uncovered

and observed in the bottom layer'of tension reinforcing. - All reinforc-ing steel was observed in the bottom layer of reinforcing for beams 283 and 2825.

I e On beam 2B3 the wood has been removed.. The piece is a shim 5 5/16" long by 1/2" wide by 3/8" thick. This material was laying parallel to the-bottom surface of the beam. An~ analysis will be prepared to show that, I while the presence of foreign ~ matter was not in accordance with procedure j or code requirements, the' ultimate capacity of the beam will1not be:

affected.

Preliminary analysis of these conditions lead us 'to these' conclusions.

i e The areas of poorly consolidated grout indicate a problem in.thel quality.

of the original patch placement on beams.2811 and 2825, both of which: ,

L were placed and patched by Contract 6426.-

e The violation of the ACI code spacing requirements for reinforcing bars in beams 2Bil and.2825 could result:in loss of stress-transfer, possibly.

reducing the ultimate design load capacity of the concrete beam.

! o The dowel.in beam 2Bil, which has not been locatedfas yet, could affect the ultimate design: load capacity-of the beam and place-in' question.the' adequacy of the in-process-quality control inspections; performed in the; original construction.. The chipping of beam.2B11 must.be done with cau-tion because the. area of excavationsis-in the shear zone of the beam

• and could.cause beam damage. - -

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Actions Taken to Preclude Reoccurrence t i The Supply System has directed the followingiactions-be; undertaken to ad--

, dress'the-nonconforming conditions.-

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.e Poor Grout Consolidation (Beams 2B11 and 2825)

A review of nonconformance reports identifying locations of honeycombs or voids repaired by Contract 6426 will be made. These patches will be checked visually and by " sounding" for integrity. In areas of con-gested reinforcing steel in beams, inspection will not be limited to Contract 6426, but will include a sampling of all contracts. Where dis-crepant work is identified, a nonconformance report will be written and corrective action taken.

e Violation of ACI Code Spacing Requireuents (Beam 2811 and 2B25)

- Areas of congested reinforcing steel are being identified by a research of plans and quality documentation. An inspection will be made of the concrete surface at these locations, and where there are any indi-cations of poor consolidation, the area will be excavated. Any discre-pant findings will be identified on nonconformance reports for disposi-tioning h the A/E.

- An investigation is underway to identify other work approved by the ,

quality control inspectors responsible for accepting tne discrepant rebar placement and these areas will be investigated to determine if similar nonconformances exist.

- All identified nonconformances will be reviewed by the A/E to determine the effects on the design load capacity of the structures.

- A review will be made of quality documentation and receiving records to confirm rebar grade and size utilized is correct and the potential for inadvertent substitution in critical areas of the Reactor Building is negligible.

e Unable To Locate Beam Dowel (Beam 2811)

An analysis will be performed on the effect of this discrepancy, and any others encountered during this investigation on the ultimate beam capacity. Upon completion of this review, necessary corrective action will be taken.

Current Status The review of contractor documentation and exploratory chipping is continu-ing. When the analysis of these results is complete, a final report.will be issued defining the full scope of the discrepancies encountered and con-taining a schedule for completion of any corrective work required.

This report is provided as an interim report. The final report'will be transmitted'by July 29, 1983.

B. Criterion XIII of 10CFR50 Appendix B states, in part, that " Measures .shall be established to control handling, storage,...and preservation of material and equipment...to prevent damage or deterioration."

Page 4 of 7

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The FSAR Section C.3.33 identifies that WNP-2 generally complies with Regu-

, latory Guide 1.38-77 (ANSI-N45.2.2). Section 6.5 of the ANSI-N45.2.2 describes inspection and care of items which have been placed in their final

locations within the power plant, and invokes requirements of Section 6.4.1 1 and 6.4.2 which requires installation of protective covers and seals over L openings, and "... Covers removed for internal access at any time for any reason .shall be immediately replaced and resealed after completion of the purpose for removal." The Bechtel implementing procedure (SWP/P-G-6 part 4.4.1) requires that, " Tight-fitting end caps, closures, plugs, etc.. shall remain in place until it is necessary to continue fabrication, installation or inspection..."

Contrary to the above, on April 22, 1983, the work area in the vicinity ,

of containment isolation valves FDR-V-3 and FDR-V-4 contained evidence of failure to provide measures to prevent damage to material and equipment, j such as: damage to flexible conduit for valve HPCS-V-23; damage to tubing i for air operator of valve FDR-V-3; . debris, tools and. arc welding equipment

! on electrical caoles in trays for liPCS equipment; and absence of pipe caps on air operators of valves FDR-V-3 and FDR-V-4.

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

i SUPPLY SYSTEM RESPONSE:

Corrective Action Taken/Results Achieved 4

i e Construction Forces I

- All construction personnel have been or will be reminded of thelimpor-tance of preventing damage to installed equipment. This is accomplished i

through the use of correspondence from the site. Construction Manager, which is discussed with General Foremen and Construction Superintendents i at a weekly safety meeting. This information is, in turn, disseminated to all construction and craft personnel during weekly safety and train -

! ing sessions held at the various job locations within the plant. This -

letter is also forwarded to all site contractors-for training of ~ con-i tract personnel.

- In addition, a job-site procedure, Project lianagement Instruction (PMI-9-2.1, was issued May 26,'1983, to implement the use of a standardized.

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}E fom to docua nt construction deficier.cies or, systeas and equi;nant which are in the custody'of the Supply System. Discrepancies of the. -

type noted in the' subject NRC' report are then tracked and included.

, as restraints to system and/or. facility _ turnover, as necessary..

- Bechtel . Quality Control has implemented a. weekly housekeeping. surveil lance program to identify cleanliness-related deficiencies which.are, in. turn, transmitted to construction supervision _for' resolution. .This

'is.an ongoing program and is expected to remain in place ^until site construction activities-are completed. ~

e Operatio'nal Forces l - The specific deficiencies identified in the" subject NRC inspection ?

l report have been documented byithe Supply System on Startup Work 3 Requests and Startup. Deficiency Reports. These items will be corrected.

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- A twice-weekly training schedule has recently oeen implemented for Startup and Operations personnel, which includes discussions of main-tenance of installed equipment and plant housekeeping.

- An Access Control Plan has recently been instituted to limit personnel access to various rooms or areas which have been turned over to Supply Systen custody. Critical areas, such as Diesel Generator Rooras, upper elevation Refueling Platforia and Circulating Water Pumps, now require written authorization for entry (i.e., level 1 Access Control). Less stringent control measures exist for Level 2 and 3 Access; however, personnel access is restricted and periodic surveillance of these areas is performed by the Supply System.

Action Taken to Preclude Reoccurrence The apparent cause of this deficiency was failure oy the Construction ilanager to assure craft understand tne implications of damaging safety-related naro-ware and then failure on the part of craft forces to recognize and report deficiencies.

e Construction Forces A supplemental letter.from the site Construction i.lanager was issued June 27, 1983 and will be discussed with all construction and contractor personnel. This letter describes specific types of deficiencies similar to those addressed in the NRC report. The letter also requests all per-sonnel to identify any cases of damage to installed equipment to super-vision so that repairs can ce completed. Training of the construction and contract personnel is scheduled to be completed no later than July 15, 1983.

e Operational Forces Increased implementation of the Access Control Plan previously described will continue as the bulk of construction is completed and the Operations Group obtains custody of a larger percentage of the power plant.

Date of Full Compliance Full ;wpliar.= ..ill ca c;hievad no later then July 15, 1933,'.. hen ;h: ce;-

plemental training will be completed.

C. 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 i'iS39 and Table 3.2.1 identify the piping and associated components of the floor drain system, upstream of primary contain;aent isolation valve FDR-V-4, as Quality Class I. This invoked appropriate quality standards and related quality control inspections.

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• , Page 6 of 7 Contrary to the 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 identi-fied by the signatory 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 SYSTEH RESPONSE Corrective Action Taken/Results Achieved As a result of this item of noncompliance, a review of all hangers listed in ped 215-H-G046 was completed. This review consisted of a detailed exam-ination of all fabrication isometrics associated with the listed hangers.

The fabrication isometrics were then reviewed for compliance with the appro-priate Burns and Roe flow diagrams.

Four PED's have been issued to correct improper quality class downgrading as a result of PED 215-H-G046. PED 215-H-ti390 issued April 26, 1983 cor-rected the specific improper quality class dovingrading of FDR-900il as iden-tified in Inspection Report 83-14. In addition to this PED, three other corrective action PED's have been issued: PED 215-H-M182 (issued 4/5/83);

PED 215-H-N178 (issued 4/27/83); PED 215-H-l4962 (issued 5/18/83).

Additionally, a thorough review of all PED's pertaining to the downgrading of supports was conducted. Forty-four Quality Class I hangers were identi-fied as being improperly downgraded. Four PED's have been issued as correc-tive actions: PED 215-H-H971 (4/22/83); PED 215-H-N510 (5/6/83); PED 215-H-N604 (5/12/83); PED 215-H-P742 (6/8/83).

Action Taken to Preclude Reoccurrence The transmittal requested a discussion of how the Burns and Roe design >

control process could have permitted the incorrect downgrading to occur. ,

The intent of the downgrading was to reclassify from Quality Class.I to Quclity ;1 css II, han;crs :nd ::cntrols on piping system that =re net nuclear safety-related. The hangers and controls had been classified Qual-ity Class I because they were (and are) designed to Seismic Category I requirements.

ilechanical engineers prepared a listing of fabrication isometrics versus quality class for systems eligible for downgrading of _ hangers. This list-ing was then given to the hanger discipline engineers to develop a listing of specific hangers that could be downgraded. This listing contained several cases of fabrication. isometrics which had dual quality classifi-cation (both Quality Class I and Quality II). It appears that the Quality Class I components on the fabrication isometrics may not have been'specifi -

cally identified in the listing, and that the hanger discipline misunder-stood the significance of the dual quality classification, and improperly reclassified all hangers on the isometric to the lowest quality class, i e.g., Quality Class II. -!

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Page 7 of 7 In each discipline, mechanical and hangers, it appears that no checking was performed of each discipline's own work. Since mechanical engineering provided a listing of fabrication isouetrics versus quality class to nanger engineering, the listing should have been checked.for correctness by another Hechanical Engineer. Since Hanger Engineering used the isometric listing to develop another listing of hangers versus fabrication isometric, the hanger discipline should have checked the later listing for correctness.

The root cause for the improper downgrading was specifically that Quality Class I work was not checked by an independent reviewer. Detcils are:

e Quality Class I affecting work was not checked by an independent re-viewer.

Burns and Roe Project Instruction UNP-2-017, Exhibit IV, Paragraph A.2.c(1) clecrly requires checking of wo.-k associateo with Quality Class I work. In Revision 6 of the procedure (effective at the time the PED was processed, the requirement is that the Group Supervisor"...

verifies or causes to be verified the design content of the PED oy execution of the Design Verification Checklists (Exhibit XXI)." The Design Verification Checklist, Item 3.0, is "Are tne appropriate qual-ity and quality assurance requirements specified?", which if performed properly, would have identified that Quality Class I hangers were being improperly downgraded.

In addition to issuance of PED's correcting technical direction, group supervisors and project engineers will receive refresher. training on implementation of WNP-2-017 related to checking design docts.ients.

This training will be complete by June 30, 1983.

Date of Full Compliance Only one PE0 remains to be issued to correct improper quality downgrading of PE0 215-H-G046. This PED will be issued by June 30, 1983 Training is scheduled to be complete by June 30, 1983.

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