GO2-83-847, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-38.Corrective Actions:All Weldolets on Six Separate Tree Risers Inspected & Found Fully Welded Out.No Deficiencies Encountered

Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-38.Corrective Actions:All Weldolets on Six Separate Tree Risers Inspected & Found Fully Welded Out.No Deficiencies Encountered

ML20078G328
Person / Time
Site:	Columbia
Issue date:	09/19/1983
From:	Carlisle C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20078G325	List: GO2-83-847, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-38.Corrective Actions:All Weldolets on Six Separate Tree Risers Inspected & Found Fully Welded Out.No Deficiencies Encountered
References
GO2-83-847, NUDOCS 8310120196
Download: ML20078G328 (8)

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Washington Public Power Supply System .

P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509)372-5000 Docket No. 50-397 September 19, 1983 G02-83-847 Mr. J. B. Martin Regional Administrator U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596

Subject:

NUCLEAR PROJECT NO. 2 tRC INSPECTION REPORT 83 NOTICE OF VIOLATION

Reference:

Letter D. M. Sternberg to C. S. Carlisle, dated August 30, 1983 Washington Public Power Supply System hereby replies to the Notices of Viola-tion designated "A" and "D" in Appendix A of the referenced letter.

Our replies, 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 Attachments 1 and 2 which contain our responses to these Notices of Violation.

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

- 901A Program Director, WNP-2 HAC/1kh cc: Mr. R. C. DeYoung, NRC I&E Mr. R. T. Dodds, NRC RV Mr. R. F. Heishman, NRC QASIP IE Mr. A. D. Toth, NRC Resident, WNP-2 ,

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8310120196 830928 PDR ADOCK 05000397 G PDR

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Attachment-1 WASHINGTON PUBLIC POWER SUPPLY SYSTEM ftJCLEAR PROICT NO. 2 000(ET NO. 50-397 LICENSE NO. CPPR-93 RESPONSE TO INSPECTION REPORT 83-38 NOTICE OF VIOLATION

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Statement of Violation

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'"As a result of the special inspection conducted by the E C Construction Ap-praisal Team on May 16-27 and June 6-22, 1983, and in accordance with the EC Enforcement Policy,10 CFR Part 2 Appendix C, the following violations were identified:

Criterion V of 10 CFR 50 Appendix B requires, in part, that " Activities affec-ting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished

-in accordance with these instructions, procedures or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance . criteria for determining that important activities have been sat-isfactorily accomplished."

The FSAR for the WNP-2 project, Section 17.1.1.5, accordingly describes that activities affecting quality are described in procedures, instructions, and drawings and that activities are conducted in accordance with these docu-

.ments. Procedures, instructions, and drawings include adequate quantitative and qualitative acceptance criteria to ascertain that the prescribed activi-ties have been satisfactorily accomplished.

- A. The approved procedures and specifications for installation of weld-o-let fittings requires 100 percent reinforcament of attachment welds.

Contrary to Criterion V, 10 CFR 50, Appendix B, cited above, and the above requirement, weld-o-let fittings have been installed and accepted by quality control inspectors with less, that (sic) the 100 percent rein-

! forcement of the' attachment weld as observed at the time of the inspec-l tion on the four-inch weldolet installed at HPCS-630-ll.12/COND-356-9.12.

This is a Severity Level IV Violation, (Supplement II)."

Supply System Response An isometric drawing review was made of all weldolet type branch connec-

! tions (weldolets [B E], laterolets [B N], elbolets [B E], elbow pipets

[WFI], lateral pipets [WFI), pipets [WFI], bossets (WFI), sockolets [BN],

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. 3 and stainless products olet fittings) contained in contracts 215 and 220 work scope. Eight hundred twenty-three (823) olet type fittings were identifled. - This represents 100 percent' of the olet fittings. Eight fittings were not reinspected due to inaccessibillty by being either buried or under water. Of the 815.that were inspected, 714 were accept-able, being in strict conformance with the manufacturers' requirements.

One hundred one (101) olets inspected were not in strict conformance with the manufactur'ers requirements. Of the 101 nonconformances, 64 are of a

. minor nature (minor underweld/ concavity, minor contour anomaly,' minor lapping at weld edge, minor post weld surface preping/ grinding, missing fillet cap [WFI only), abrupt transition to run pipe) and are expected to be dispositioned as acceptable by the engineer. The remaining 37 contain underwelds greater than 1/8" or more serious contour anomalies. All 101 were identified on NCRs. The Architect Angineer (Burns and Roe) will evaluate each of the 101 on a case-by-case basis documenting the results in accordance with existing project procedures. . If the nonconformance meets all code requirements (NX-3000) for pressure and structural inte-grity for all modes of operation, the joints will be dispositioned as l

" acceptable as is". If not, the joint will be repaired.

No other contractors on the project used appreciable numbers of olets, with the exception of Contract 233.

Welding out of Weldolets installed under Contract 233, " Spray Pond Pip-ing", was reinspected by the Special PPIA Review Task Force. All weld-olets on six separate " tree risers" were inspected, three on each spray pond, which constitutes a 10 percent sample. All were found to be fully welded out, with no deficiencies encountered.

Corrective Action to Preclude Repetition This program covered 100 percent of the population. Inspectors have been retrained. - Deficiencies have been recorded 'as nonconformances and will be evaluated by the engineer and repaired if necessary.

Date of Full Compliance All nonconformances are scheduled to be dispositioned and required rework complete by November 1, 1983.

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Attachment 2 WASHINGTON PlBLIC POWER SUPPLY SYSTEM  ;

MJCLEAR FROICT NO. 2 DOCKET NO. 50-397 '

, LICENSE NO. CPPR-93 RESPONSE TO INSPECTION REPORT 83-38 NOTICE OF VIOLATION Statement of Violation i "As a result of the special inspection conducted by the NRC Construction Ap-praisal Team on May 16-27 and June 6-22, 1983, and in accordance with the NRC Enforcement Policy,10 CFR Part 2 Appendix C, the following violations were Identified:

Criterion V of 10 CFR 50 Appendix B requires, in part, that " Activities affec-ting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Instructions,

, procedures, or drawings shall include appropriate quantitative or qualitative

' acceptance criteria for determining that important activities have been accomplished.

The FSAR for the WNP-2 project, Section 17.1.1.5, accordingly describes that activities affecting quality are described in procedures, instructions, and drawings and that activities are conducted in accordance with these docu-ments. Procedures, instructions, and drawings include adequate quantitative and qualitative acceptance criteria to ascertain that the prescribed activi-ties have been satisfactorily accomplished.

ED. . Contrary to Criterion V, 10 CFR 50, Appendix B, cited above, installed bolting materials for the following equipment and structures were not in accordance with the applicable design drawings and specifications when

-observed during the inspection.

1. - ASTM A-194 Grade 2H nuts were installed in lieu of Grade 7 on var-ious bolts, in the motor-pump couplings of pumps Rm-P2A, Rm-P2B, Rm -P2C, HPCS-P1 and LPCS-Pl.

2. One ASTM A-194 Grade 2 nut was installed in lieu of Grade 2H on pump

SLC-Pl A.

3. Not all nuts were the required ASTM-A-194 Grade 2H in the relief valve SLC-RV-29B and pump RRC-P-1B penetration 41-e. The grade of these nuts was unknown.

This is a Severity Level IV Violation (Supplement II)."

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Supply System Response The Supply System has reviewed bolting materials in various applications throughout the plant, since the CAT inspection, to determine compliance with design drawings and specifications. These sample inspections were established to obtain a representation of all major installers' installa-tions and were based on obtaining a 95 percent confidence level that less than 5 percent of the total fasteners were different than specification requirements using standard statistical methods. The 95 percent confi-dence level is. the same as that used by the NRC in Bulletin IE-79-02 Appendix A for evaluation of concrete expansion bolts, which is a similar situation as the fasteners reviewed here.

In total, the Supply System has reinspected over 6,000 individual fast-eners and has found that the number of material deviations are within the 95 percent confidence level. Following is a breakdown of these inspec-tions by bolting type:

Inspected Defects Pipe Flange Bolting 4238 139 Valve Bolting Pressure Boundary 1322 46 Non-Pressure Boundary 352 10 ECCS Pump Assembly Bolting 459 7 TOTALS 6371 202 Responding to the three items specifically mentioned, the following has been done:

1. All of the ECCS pump coupling bolts and nuts have been reinspected for proper material. While it is true that Grade 7 nuts were spec-ified for these pumps, the Grade 2H nuts installed are technically acceptable since the only difference is the minimum tempering temp-erature. Grade 7 nuts are tempered at 1100oF and Grade 2H nuts are tempered at 8500F. Since the pump coupling bolts operate at a rela-tively low temperature, this difference in nut grade does not affect the structural adequacy of the installation. Test and Startup re-moves, bags, and replaces the same bolting material, so it is pos-sible that the 2H nuts were supplied by the pump supplier, Ingersol Rand.

In addition to the ECCS Pumps, the following twelve additional pump groups are being inspected or reinspected for proper coupling bolt material.

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1. RWCU-P-1A - Cleanup Circulating Pump RWCU-P-1B - Cleanup Circulating Pump

2. RCIC-P RCIC Pump

3. 'HPCS-P HPCS Water Leg Pump

4. CRD-P-1A - CRD Pump CRD-P-1B - CRD Pump

5. FPC-P-2A - Fuel Pool Holding Pump FPC-P-2B - Fuel Pool Holding Pump

6. TMU-P-1A - Cooling Tower Makeup Pumps TMU-P-1B - Cooling Tower Makeup Pumps TMU-P-lC - Cooling Tower Makeup Pumps

7. TSW-P-1A - Plant Service Water TSW-P-1B - Plant Service Water

8. FP-P-1 - Fire Pump FP-P-2A - Fire Pump FP-P-2B - Fire Pump FP-P-3 - Fire Pump FP-P-101 - Fire Protection Pump FP-P-102 - Fire Protection Pump FP-P-110 - Fire Protection Pump

9. CO @ -P-1A - Condensate Pump COND-P Condensate Pump CO 2 -P-lC - Condensate Pump

10. COND-P-2A - Condensate Booster Pump.

CO2-P-2B - Condensate Booster Pump COND-P-2C - Condensate Booster Pump

11. SW-P-1A - Standby Service Water Pump SW-P-1B - Standby Service Water Pump

12. CO2-P Reactor Building Condensate Supply Pump COND-P Radwaste Building Condensate Supply Pump CO2-P Condensate Filter /Demineralizer Backwash Pump To date, approximately 50 percent of these pumps have been reinspected with no identification of improper material.

2. Both of these items concern nuts of improper or unknown grade on flanged connections. The Supply System performed the following evaluation specifically for flange bolting.

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,.. o, PIPE FLANGE BOLTING Sample Evaluation MATERIAL I I I I I I I

.l l Sample Size l Material I Nuts I I l l l Studs l l Variations l Turned l Nuts l l

.l Installer I or Bolts.I Nuts l Studs l Nuts l Over l Unknown l I I I I I l Supplier l 32 l 64 1 0 1 7 l 4 1 3 l l l l l 1 I I I I I l C-233 l 120 l 120 1 0 1 0 1 0 1 0 l l I I I I I I I I I

-l C-220 1 32 1 56 1 0 1 0 l 1 1 0 l l l 1 1 I I I I I I I C-215 l 807 l 959 l 43 l 15 1 23 l 17 l l l 1 1 I I I I I I l C-250 l 419 l 592 1 10 l 56 l 16 1 31 l l l l l l 1 I I I I I Test & I I l l l l l l l Startup l 461 l 700 1 0 l 8 l 25 1 4 l l 1 I I l l l TOTALS 1,871 l 2,491 53 1 86 69 I 55 l l I I I I l TOTALS l 4,362 l 139 I ]?4 l l Of the total of 4,362 fasteners inspected,124 are nuts which would require removal to check for identification. Sixty nine of this 124 are clearly turned over so the identification marks were inaccess-ible. The other 55 nuts were inaccessible for identification for a variety or reasons such as paint, insulation, access, turned over, etc . To properly account for material variations that could exist in this 124, a percentage of exceptions was established using the total population of 4,362 reduced by the 124 giving 139 exceptions in a population of 4,238. This results in a possible 5 additional exceptions in the 124 nuts.

Therefore, in the total population of 4,362 fasteners a total of 144 exceptions could exist.

The allowable number of exceptions for a sample size of 4,362 is 194 to maintain a 95 percent confidence level that there are less than 5 percent material variations in the population not inspected.

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ihe sample shows that the material used in Quality Class I flange bolting is acceptable. Specific exceptions to specified materials identified in the inspection sample will be corrected by December 1, 1983.

A review of flange bolt loading was performed with Burns and Roe.

The actual flange bolt loading is generally much less than the al-1cwable bolt loading. These additional design margins are beyond the conservatism inherent in flange bolt loading design, providing addittonal assurance that a random nut or stud of a lesser tensile strength (A-307 versus A-193) is of no concern. Of the 53 stud material variations 43 were A-307 and 10 were unknown. Of the 86 nut variations 81 were A-307 and 5 had identification marks which could not be identified. However, the minimum material used is A-307, since this is the lowest grade commercially available for this type of fastener.

Corrective Action to Preclude Repetition The number of deficiencies found do not indicate a generic problem with fastener materials. The emphasis placed upon compliance with specifica-tion requirements or fastener installations by the thorough review con-ducted by the project, following the CAT audit, has sensitized organiza-tions participating in field work to the requirements of the specifica-tions, procedures, and responsibilities for compliance.

The Bechtel warehouse for fasteners, which is also used by the Supply System Test and Startup, was reinspected and material segregation pro-blems were corrected.

The overall WNP-2 fastener review / inspection program identified work on locking devicas and equipment mounting that was generically unacceptable and for which reinspection / rework is being implemented.

Date of Full Compliance Results of extensive sample inspections indicate that WNP-2 fastener mat-erials are in compliance with design drawings and specifications with a 95 percent confidence level that less than 5 percent defects exist.

Specific deficiencies identified in the sample inspections will be cor-rected prior to Decemtser 1,1983. Reinspection and rework implemented to correct the problems identified on locking devices and equipment mounting will likewise be completed prior to December 1, 1983.

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