IR 05000397/1979001

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IE Insp Rept 50-397/79-01 on 790103-05.Noncompliance Noted: Cleanliness of Safety Components
ML17272A331
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 01/24/1979
From: Bishop T, Haist D, Haynes R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17272A329 List:
References
50-397-79-01, 50-397-79-1, NUDOCS 7903210025
Download: ML17272A331 (27)


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S NUCLEAR REGULATORY COB!'1ISSION OFFICE OF INSPECTION AND ENFORCEt1ENT REGION V

Report No.

50-397/79-01 Docket No.

50-397 License No.

CPPR-93 Safeguards Group Licensee:

Washington Public Power Supply System P. 0.

Box 968 Richland, Washington Facility Name:

Washington Nuclear Project No.

(WNP-2)

Inspection at:

WNP-2 Site, Benton County, Washington Inspection Conducted:

January 3-5, 1979 Inspectors:

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T.

W. Bishop, React r Inspector

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D. P. Haist, Reactor nspector C~

a G. Hernandez, Reactor I

pector pc Date Signed a

Date Signed J97g Date Sig'ne Approved By:

Summary:

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C. Hayes Lhi rojects Section, Reactor Date Sign Construction and Engineering Support Branch Ins ection on Januar 3-5, 1979 (Re or t No. 50-397/79-01)

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d'I of construction activities including:

safety related components installation gA implementing procedures, observations of work activitie's, and review of quality records; review of instrumentation gA implementing procedures and implementation status; review of piping penetration ouality records; review of preparation for preservice examinations; follow-up on previous inspection findings; and tour of plant areas.

The inspection involved 54 inspector-hours onsite by three NRC inspectors.

Results:

One item of noncompliance was identified in the seven areas inspected

~Infraction - clean'liness of safety related components, Paragraph 4.b).

7 908 21 Ogp-5 IE:V Form 219 (2)

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DETAILS Persons Contacted I

llashin ton Public Power Su lv S stem

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D. Kohler, )NP-2 Project Manager Janus, Construction Manager Taimer, Construction Superintendent L. Howard, Operational guality Assurance Manager M. Sastry, tNP-2 Project guality Assurance Manager D. Martin, Startup and Operations Manager D. Cowan, Project Engineering Manager R. Holder, lliRP-2 Assistant Superintendent T. Harrold, Supervisor, ISI Programs K. Afflerbach, Supervising Test Engineer F. Peters, Startup Administrative Supervisor L. Stevens, guality Assurance Engineer, Civil Schutte, Mechanical Engineer Shearer, (juality Assurance Engineer, Mechanical D. Smith, Lead Engineer, gCSSI J.

Hanna, Supervisor, gCS8I F. Blanker, Supervisor, ISI 8 Operations Support M. Porter, Lead Engineer, ISI Timmons, Project Engineer, (li'rP-2 Burns 5 Roe, Inc.

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Root, Deputy Project Manager J. Parise, Deputy Project guality Assurance Manager A. Lacey, Resident Project Engineer Harper, Technical Support Manager Akers, Sr. Melding Engineer Tuthill, Sr. Project guality Assurance Engineer Reader, Lead equality Assurance Engineer - Mechanical Massman, Sr. guality Assurance Engineer - Electrical Keating, Supervising Metallurgical Engineer Hudak, equality Assurance Engineer Carmichael, Lead guality Assurance Engineer - Electrical Rapp, Civil Engineer Alexandrow, Mechanical Enginee~

WSH/Boecon/Bovee and Crail/GERI E. A. Harrington, General Project Manager A. Larson, Quality Assurance Manager L. Buckner, Quality Control Supervisor G. Durkee, Quality Engineer P.

Young, Quality Control Inspection Supervisor D. Mitchell, Lead QC Inspector Pittsbur h-Des Moines (PDM)

F. Lynch, Quality Control Supervisor Fischback/Lord J. Collins, Quality Assurance Manager H. Zimmerman, Quality Assurance Engineer Peter Kiewit Sons (PKS)

C. Ferguson, Quality Assurance Manager L. Lindman, Quality Assurance Engineer Johnson Consrols~Inc.

JCI)

L. Hordquist, Assistant Project Manager J. Hardin, Project Superintendent R. Jones, Quality Assurance Manager R. Swift', Quality Assurance Engineer

  • Denotes those present at exit interview.

In addition, Mr. G. Hanson, Senior Project Engineer, Energy Facility Site Evaluation Council of the State of 'li'ashington, attended the exit interview.

Construction Status As of December 22, 1978, the licensee considered the construction of llNP-2 project to be 74/ complete.

Licensee Action on Previous Ins ection Findings a.

Licensee response to the following items of noncompliance was examined:

(1)

(Closed)

Noncompliance (50-397/78-03/Ol):

Modifications had been accomplished on pipe supports without the requir ed approval.

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(2)

(Closed)

Noncompliance (50-397/78-03/02):

Pipe supports were not installed in accordance with prescribed instructions, procedures, and drawings.

(3)

(Closed)

Noncompliance (50-397/78-03/03):

Inspections

. of pipe supports were not adequately performed.

(4)

(Closed)

Noncompliance (50-397/78-03/04):

Nonconforming conditions existing in accepted pipe supports were not documented and processed in accordance with established procedures.

.(5)

(Closed)

Noncompliance (50-397/77-07/01):

Pipe support quality records were deficient as evidenced by incom-plete checklists, missing NDE records and weld filler material withdrawal forms, and lack of traceability between welds, welders and gC inspectors.

Licensee response was surrmarized in WPPSS letters Nos.

G02-78-91 of March 10, 1978, and G02-78-217 of August 31, 1978.

The programmatic revisions, retraining commitments, and nonconformance documentations were examined during pre-vious NRC inspections and were found satisfactory.

The inspector was advised that additional record reviews and inspection training had been performed since pipe supports were last examined by the NRC (Inspection Report No.

50-397/78-10).

The implementation effectiveness of these and previous actions taken by the licensee was examined by the independent inspection and records review of eight (8) completed pipe supports.

The supports and record pack-ages were compared against the requirements of the PSAR and applicable specifications, procedures, and drawings.

All items were found to be in compliance with these docu-ments.

This matter is closed.

b.

(Open)

Open item (50-397/78-10/07):

Inspection I'1aintenance Record form included in 'Hor k Procedure No. 23 was inconsis-tent with the procedur e text.

Work Procedure No.

23 required use of a preservative which is in apparent conflict with ANSI N45.2.1.

The licensee's contractor (WSH/Boecon/GERI)

has initiated a

task force study which will upgrade the equipment storage/

maintenance program.

Task force functions are to (1) issue

new Work Procedure No. 106 defining the Equipment Maintenance Program, (2) review all maintenance requirements for all equipment/valves and generate maintenance procedure records (MPR) for each, and (3) implement the new maintenance program including documentation and disposition of nonconformances.

The licensee's contractor expects the new program to be im-plemented by mid-February, 1979.

Regarding the use of preservatives, the licensee has determined that Tower 635RP preservative is water soluble and is recommended by the pump manufacturer.

The inspector has no further questions on this item.

An additional inconsi,stency between maintenance required and maintenance performed was noted during this inspection (see Paragraph 4.c).

The area of equipment storage/maintenance will remain an open item until Work Procedure No.

106 is fully implemented.

(Closed)

Unresolved item (50-397/78-02/02):

Inspection of completed and inprocess work on safety related components revealed instances of poor equipment maintenance and cleanli-ness control.

The inspector visually examined four of the five conditions noted in the previous inspection and found conditions adequately corrected with the exception of pump RHR-P-2C pit.

A ruptured fire line resulted in flooding of the pump pits.

The RHR pump pit was the only pit remaining to be pumped dry and cleaned.

The inspector reviewed NRC-215-4334 which will permanently solve the flooding problem and addresses the corrosion on the RHR pump casing.

The actions taken by the licensee to correct the specific conditions previously identified were found satis-factory.

This unresolved item is, therefore, closed.

However, additional instances of poor cleanliness control were noted during this inspection which resulted in an item of noncompliance.

Refer to Paragraph 4.b of this report for details.

(Open)

Open item (50-397/78-09/01 ):

Instrumentation contractor needs to develop Class I equipment installation procedures prior to the start of quality class I work.

The instrumentation contractor, Johnson Controls Inc. (JCI),

has developed and obtained licensee approval of at least two installation/fabrication documents since the last NRC in-spection.

However, other procedures necessary for proper

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9, control of quality class I work have not yet been approved for use.

In addition, certain quality procedure reauire-ments have not yet been fully implemented to allow corrmence-ment of quality class I work.

See Paragraph 5 of this report for details.

This item remains open pending develop-ment and implementation of required procedures.

{Open)

Open item {50-397/78-11/01):

Plant housekeeping requires improvement to prevent possible damage to installed safety related systems or components.

. The, licensee has initiated periodic surveillances of the plant to identify areas requiring housekeeping attention.

A tour of

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the plant areas by the inspectors revealed significant improve-ments in housekeeping in some areas (such as the 606'levation of the Reactor Building).

Other areas, such as the Diesel Generator Building, are in need of additional attention.

Dur-ing the housekeeping inspection, the inspectors observed approxi mately five unused welding rod electrodes and ten electrode stubs lying about outside of their containers.

Additional observations were made by the inspectors which indicated that this was an isolated case.

Licensee representatives stated that periodic housekeeping surveillance will include checks for uncontrolled weld filler material.

This item remains open pending completion of the licensee's actions to improve housekeeping.

(Closed )

Open item (50-397/78-11/04):

Incomplete electrical penetration receiving inspection records.

Fischbac k/Lord has verified'hat the absence of inspection check marks on the receiving inspection records was an over-sight on the part of the inspector and that the items were acceptable at the time that the receiving inspection was performed.

A letter signed by the inspector attesting to this has been included as part of the record package for the penetrations involved.

The inspector had no further questions on this matter.

This item is closed.

(Closed )

Open item (50-397/78-ll/02):

Structural fit-up bolts were left in place and not tightened, presenting a hazard (from a falling nut or bolt) to equipment located beneath the structures.

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-6-The contractor has reinspected structural fit up bolts at several Reactor Building elevations, including those identified by the NRC inspectors.

In a11 cases, untorqued bolts were either removed or torqued to an appropriate value.

The in-spectors examined a sample of the records of the reinspection and found them satisfactory.

The inspector has no further questions on this item.

Safet Related Com onents a

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Review of OA Im lementin Procedures The following contractor documents, applicable to safety related components, were examined for conformance with the:

requirements of the licensee's gA program:

(1)

Work Procedure No, GE-59, Rev.

1, Cleanliness Program and Control Procedure (2)

Work Procedure No: 106, Rev. 0, Equipment tlaintenanc'e Procedure (issued for information only)

(3)

guality Control Procedure No. 14, Rev. 4, Receiving Inspection (4)

guality Control Procedure No. 23, Rev. 0, Control of Tapes, Adhesives, and Pipe Dope Compounds.

No inconsistencies with the requirements of the licensee's gA Program were identified.

The inspector noted that Work Procedure No. 106 will be implemented as described in Para-graph 3.b of this report.

The licensee stated that Work Procedure No. 23, Rev. 1, will be used until full implementa-tion of Work Procedure No. 106.

No items of noncompliance or deviations were identified.

b.

Observation of Work and Work Activities

'Completed and inprocess work on safety related components was examined for compliance with applicable procedures and standards.

The specific components inspected included the reactor pressure vessel, control rod drive piping, penetration X-20, and valves MS-Y-28C and RHR-Y-8.

The folloviing items were noted during the inspection:

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-7-(1)

The East CRD scram discharge header piping at approxi-mate elevation 532'as found open, exposing the fluid surfaces of the piping, A cleanliness tag was attached to the piping near the open end.

No surveillance per-son'nel were in the area.

(2)

Upon removal of the closure cap and examination of the inter ior of 20" RHR piping penetration X-20 from the outboard side, the inspector found sand-like grit in the pipe and a coiled welding lead approximately 10'rom the end of the pipe.

The inboard pipe weld had been'completed and presumably inspected to Cleanliness Class

"8" criteria.

A cleanliness tag was not attached

at the closure.

A temporary material tag was not attached at the closure.

(3)

The inspector visually examined cleanliness controls at the reactor pressure vessel and found a broken lock-ing mechanism at a reactor hatch cover.

The inspector also found a plug missing from a 1 ~ inch diameter in-strument penetration.

The licensee corrected both findinqs.

(4)

The inspector visually examined partially installed valve HS-V-28C and found it clean and maintained in accordance with the applicable procedures.

The inspec-tor visually examined the interior of valve RHR-V-8, not yet installed, and found particles of metal and bits of rag.

The licensee cleaned the valve and resealed i'he failure to follow the provisions of cleanliness procedures as delineated in items (1) and (2) above is considered an item of noncompliance.

The subject of safety related component maintenance and cleanliness will be re-examined following re-ceipt of the licensee's reply to the Notice of Violation (50-397/79-01/01).

The inspector interviewed warehouse and training personnel concerning implementation of the nevi gCP No. 23, Rev. 0, Control of Tapes, Adhesives and Pipe Dope Compounds.

The inspector found that the procedure has not been formally implemented although some provisions of the procedure.are a matter of practice.

The licensee stated that the gCP will be fully implemented within two weeks.

Implementation of gCP No.

23 will be examined in a subsequent inspection (50-397/79-01/02).

c.

Review of ualit Records The quality records associated with Pump RHR-P-2C and valves RHR-Y-8 and t<S-Y-28C were reviewed for conformance with appli-cable procedures and specification requirements.

Included in the review where receiving inspection, maintenance, installa-tion inspection, and material and fabrication records and nonconformance reports.

h No items of noncompliance. or deviations were identified.

It was noted that the inspection maintenance record form NF-124 for valve RHR-Y-8 is not in accordance with the record 'form specified in Work Procedure No. 29.

This area will be 're- '

examined following implementation of Work Procedure No. 106, as noted in Paragraph'.b of this report.

Instrumentation (Com onents and S stems)

Review of A Im 1 ementin Procedures The inspector reviewed the following instrumentation contractor, Johnson Controls (JCI), procedures for compliance to PSAR commitments.

guality Assurance Procedure, gAS-601-H2, Rev. 0, Installation/Fabrication Planner Package Preparation guality Assurance Procedure OAS-602-H2, Rev. 0, Installation/Fabrication Planner Field Revision'uality Assurance Procedure gAS-201-H2, Rev; 0, Training/Indoctrination Procedure for OA Personnel guality Assurance Procedure gAS-1901-H2, Rev. 1, Audit Procedure The procedures appeared adequate for the scope of work to be performed by the contractor.

No items of noncompliance or deviations were identified.

The general readiness of other procedures was reviewed with cognizant JCI managers.

It was established that the contractor has not yet obtained approved procedures for weld rod control and pipe bending, Licensee representatives stated that these procedures would be approved and implemented prior to the start of quality class I work activities.

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b.

Procedure Im lementation Status The implementation of procedure requirements regarding gA personnel training, auditing, and work package preparation was examined.

The inspector noted that work package pre-paration requirements (identified in OAS-601-H2)

have been implemented, but that certain aspects of the OA personnel training program (i.e., performance evaluation)

and the audit program (i.e., audit scheduling)

h'ave not yet been completed.

Licensee representatives stated that the implementation status of these and other procedure requirements would be reviewed prior to the start of quality class I work activities.

Instrumentation contractor work procedure development and implementation will be. re-examined during a subsequent NRC inspection, as indicated in Paragraph 3.d of this'report (50-397/78-09/Ol).

6.

Pipin Penetration The inspector reviewed the quality records associated with piping penetration X-20 for conformance with licensee procedures.

The

. records included material certification, test data, receiving inspection, welder qualification, welding inspection, and noncon-formance reports.

The reports were found to be satisfactory.

No items of noncompliance or deviations were identified.

7.

Preservice Examination The inspector interviewed the licensee's ISI personnel to determine the current plans and schedule for preservice examination of the RPY and ASHE Class

and 2 piping and components.

Examinations will be conducted in accordance with ASHE Section XI, 1974 Edition includinq addenda through Summer, 1975.

The preservice examination plan is undergoing final licensee approval.

The preservice examina-tion of piping inside containment is expected to begin in February, 1979.

Preservice examination of the RPY is expected to begin in Fall, 1979.

Preservice examination of the RPY and Class

and 2 pi'ping will be performed by Lamber-t1cGill-Thomas.

The licensee will perform visual examinations.

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-10-Plant Tour The inspectors walked through various areas of the plant to observe the control of work activities, status and condition of taos affixed to equipment, and to examine the general state of housekeeping.

As noted in Paragraph 3.e of this report, housekeeping has improved in some areas of the plant, but requires additional attention in other areas.

Exit Interview At the conclusion of. the inspection, a meeting was held with licensee and Burns 5 Roe representatives, denoted in Paragraph l.

The activities covered during the inspection and observations and findings of the inspectors were discussed.

Licensee representa-tives stated that action would be taken on items identified during the current inspection.

During the interview, the inspectors requested that the NRC be advised approximately a week in advance of the next planned entry into the reactor vessel to allow NRC inspection of vessel internals.

Licensee representatives agreed to this request.

In addition, the inspectors requested that one copy of the preservice examination plans and procedures, Volumes I and II, be forwarded to Region V

NRC as soon as they are approved.

The licensee agreed to provide the requested material.

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Washington Public Power Supply System A JOINT OPERATING AGENCY P. Q. BOX 968 3000 GEO. WASHINGTON WAY RICHI.ANO. WASHINGTON 50552 PHONE (509) 946 960l February 22, 1979 Nuclear Regulatory Commission Region V

Suite 202, Walnut Creek Plaza Walnut Creek, California 94596 G02-79-28 Attention:

Subject:

Nr.

G. Chief, Reactor Construction and Engineering Support Branch WPPSS NUCLEAR PROJECT NO.

NRC INSPECTION - JANUARY 3-5, 1979 DOCKET NUHBER 50-397 References:

1)

Letter, G. to N. 0. Strand, dated January 24, 1979.

2)

Letter, D. F.

Knuth to all AEC Licensees.

dated December 31, 1974, HCriteria for Determining En forcement Action and Cate gori es of Non-Compliance."

Dear t1r. Spencer:

This is in response to your letter of January 24, 1979, Reference 1),

which documented the results of the NRC Inspection conducted on January 3-5, 1979 of activities authorized by NRC Construction Permit No.

CPPR 93.

This letter identified one item of noncompliance which was categorized as an infraction in accordance with the provisions of Reference 2) and required that WPPSS provide a response to this item.

The specific NRC "Notice of Violation,H as stated in your letter, and the WPPSS responses are provided in Appendix A to this letter.

If you have any questions or desire further information, please advise.

Very truly yours, D.L.

RENBERGER Assistant Director Generation and Technology DLR/JNS/lm cc:

JG Davis - Office of Inspection 8 Enforcement D

Roe, BPA

Page I of 2 APPENDIX A iington Public Power Supply System P.O.

Box 968 Richland, Washington 99352 Docket No. 50-397 Construction Permit No.

CPPR-93 Notice of Violation Based on the results of a NRC inspection conducted on January 3-5, 1979, it'ppears that one of your activities was not conducted in full compliance with conditions. of your NRC Facility License No.

CPPR-93, as indicated below.

This item is an infraction.

CFR 50, Append'ix B, Criterion V, states, in part, that, "Activities affecting quality...shall be accomplished in accordance with these instructions, procedures or drawings..."

.Paragraph D.2.5 of the WPPSS guality Assurance Program documented in the PSAR states, in part, that, "...all project contractors for the nuclear related portions of the plant wil,l be required to.have a guality, Assur-ance Program...The program shall include the following items as...

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applicable to the...construction for which the contractor is responsible."

Paragraph D.2.5.5, which follows, states, in part, that, "Activity affecting quality...shall be accomplished in accordance with...procedures..."

1.

Work Procedure No. GE-59, Rev. 1, Cleanliness Program and Control Procedure, states, in part, that, "...For cleanliness Class 'A'nd 'B'iping...removal of a sealed closure...shall be permitted only for a legitimate purpose..."

and "...During the entire time the seals and closures are removed, the open-ing shall be under direct surveillance by personnel who have been instructed in the need and method of protecting the surface from contamination..."

Contrary to the above, on January 4, 1979, the pipe closure had been removed from one end of the east control rod drive system scram discharge header piping at approximate elevation 532'xposing the fluid surfaces of the piping.

No surveil-lance personnel or workmen were in the area.

The CRD piping is classified Cleanliness Class

"B".

ACTION TO CORRECT DEFICIENCY

'he open pipe end observed by the NRC Inspection personnel on January 4,

1979 was brought to the attention of the contractor the same day.

The open pipe was inspected, found to be clean and re-sealed by the sub-

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actors personnel.

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, ACTION TO PREVENT RECURRENCE ecting with the contractor and sub-contractor personnel was held to press upon them the importance of surveillances in all areas to preclude recurrence.

Surveillances performed by the contractor since January 4,

1979 indicate compliance.

DATE OF FULL COt1PLIANCE Full compliance achieved January 31, 1979.

NOTE:

It should be pointed out that Work Procedure No. GE-59 relates

'only to GE/NED furnished N SSS piping and components to be installed by the contractor.

The contractor procedure being utilized by G.E.I 8 S.E.,

(sub-contractor),

for the CRD discharge piping is procedure IV-E-101, Rev.l,

"General Cleaning and Cleanliness Requirements."

2.

Work Procedure No. 59, Rev.3, Cleanliness Program and Control Procedure,.states, in part, that for Cleanliness Class 8 systems,

"...The surface shall be free of particulate contaminants such as sand, metal chips..."

and "...Any temporary material...left inside equipment shall be controlled...After installation of temporary hiaterial, the gC inspector shall attach a Temporary Material Tag where the temporary material is to be retrieved..."

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Contrary to the above, on January 5, 1979, a heavy layer of grit material and a coile'd welding'lead were inside the 20-inch diameter residual heat removal system piping at penetration X-20.

The inboard pipe weld had been completed.

The grit was distributed throughout the pipe and the weld lead was located approximately ten feet from the open outboard end of the pipe.

A temporary material tag was not attached to the pipe closure.

The RHR piping is classified as Cleanliness Class B.

ACTION TO CORRECT DEFICIENCY

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The subject penetration X-20 was cleaned, material removed and resealed on'-January 5,

1979.

A sampling of containment penetrations inspected immediately subsequent to the NRC inspection were found to be substantially clean.

ACTION TO PREVENT RECURRENCE Work Procedure WP-59 is being revised to clarify cleanliness requirements.

Cleanliness during construction operations will be verified on weld records by sign-off on weld record for each welded joint.

Clean tagging of systems will take place immediately after system flush completion.

Additionally, (}uality Control Surveillances for over all cleanliness is being performed on a regular basis, and construction craft personnel have been instructed to exercise care in the ning and closing of pipes and components.

OF FULL COMPLIANCE Full compliance will be achieved by March 15, 1979,

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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION V

SUITE 202, WALNUT CREEK PLAZA 1990 N. CALIFORNIA BOULEVARD WALNUTCREEK, CALIFORNIA 94596 fII~S"~

7 t979 Docket No. 50-397 Washington Public Power Supply System P. 0.

Box 968 Richland, Washington 99352 Attention:

Hr. N. O.Strand Managing Director Gentlemen:

Thank you for your letter dated February 22, 1979, informing us of the steps you have taken to correct the items which we brought to your attention in our letter dated January 24, 1979.

Your corrective steps will be verified during a future inspection.

Your cooperation with us is appreciated.

Sincerely, gJ G. S.

S encer, Chief.

Reactor Construction and Engineering Support Branch

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