IR 05000460/1980006
| ML20008E339 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 07/09/1980 |
| From: | Bishop T, Dodds R, Hernandez G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20008E333 | List: |
| References | |
| 50-460-80-06, 50-460-80-6, 50-513-80-06, 50-513-80-6, NUDOCS 8010240587 | |
| Download: ML20008E339 (10) | |
Text
{{#Wiki_filter:kj , U. S. NUCLEAR REGUIATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
50-460/80-06 Report No.
50-513/80-06 Docket No., 50-460, 50-513 License No. CPPR-134 & -174 Safeguards Group Lit
- e
Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 Facility Name: Washington Nuclear Project Nos. 1 & 4 (WNP 1 & 4) Inspection at: WNP 1/4, Site Benton County, Washington Inspection conducted: April 29 - May 2, 1980 Inspectors: - - _ g/9 /h 4<-T. W. Bisho @ ctor Inspector Date Signed 0 0 /& 7/9/80 5/ Hernandez, Rie/ctor Inspector ' Date Signed ' Date Signed 7/ 9 / Ace Approved By: - ~ 5[.< R. T. Dodds, @, Engineering Support Section Date Signed Reactor Construction and Engineering Support Branch Summary: Inspection during the period April 29 - May 2, 1980 (Report Nos. 50-460/80-06 and 50-513/80-06 , Areas Inspected: Routine unannounced inspection by the regional based inspectors 'of activities relating to pipe support and restraint systems, electrical components and systems, licensee action on previous inspection findings, and general construction and housekeeping activites.
The inspection involved 46 inspector hours onsite by two NRC inspectors.
Resul ts: Of the five areas inspected, two items of noncompliance were identified.
(Infraction - failure to properly store and protect safety related equipment - Para. 3; infraction - failure to install pipe hanger in accordance with instructions - Para. 4b.)
In addition, a continuing item of noncompliance concerning contractor drawings was identified - Para. 2a.
RV Form 219 (2) 8010249.577 _ . -
. . . . _ DETAILS - 1.
Persons Contacted The inspectors interviewed various engineering, management, inspection and supervision personnel of the organizations listed below.
Key personnel including those who attended the exit interview are specifically identified below, a.
Washincton Public Power Supply System (WPPSS)
- J. P. Thomas, Deputy Project Manager
- T. J. Houchins, Project QA Manager
- G. K. Dyekman, Project Engineering Manager
- A. M. Sastry, Project Management Specialist
- M. C. Carrigan, Construction Manager b.
United Er sneers and Constructors (UE&C)
- E. C. Haren, Deputy Project QA Manager
- G. E. McIntosh, Assistant Deputy Project Manager c.
J. A. Jones Construction Company (JAJ) B. Roe, Project QA Manager J. Fielder, QA Engineering Supervisor
- (
d.
State of Washington
- G. Hansen, EFSEC
- Denotes attendance at the exit interview on May 2,1980.
2.
Licensee Action on Previous Ins ~pection Findings a.
(0 pen) Noncompliance (50-460/513/79-02/08): Contractor's drawings for the installation of the diesel generators were not posted with the WPPSS quality class designation.
The inspector had previously reviewed the licensee's response to the subject noncompliance (reference IE Inspection Report No. 50-460/79-07).
At that time it was noted that the licensee had requested the contractor to resubmit the drawings with the proper quality class designation and had instructed all field P'oject Engineers and Design Supervisors (MemorandumNo. 6702.001) to check the quality class designation on all documents prior to issue.
During this inspection the ten drawings in question were re-examined. The inspector noted that five of the ten drawings had been revised.and reviewed by cognizant engineers and issued, yet the quality classification had not been designated on the drawings.
These drawings were: - - -. , -. _ .-
. _. __. _ _ _ .. _ ., __ __ _ _. _ _ - -2- . . . -Drawing No.
' Revision - Ti tl e New Revision a) 9779-20243 Revision 1.
Foundation
- b)
09-810-75084-R9 vision D.
JW Piping. Schematic E . c)- 09-805-75084' Revision D Exhaust. Intake and E . Crankcase Piping Schematic d) 09-827-75084 Revision D Fuel Oil Piping Schematic F , e) R3939 Revision E Installation Drawing DSRV-16 G , The corrective action taken on this noncompliance appears to be
inc]mplete and this ' matter is considered to be a continuing item ~ of noncompliance.
b.
(Closed) Unresolved Item-(50-460/513/78-08/03): Improper storage and handling of stainless steel liner plate.
The storage and handling of the subject liner plate had been cbserved by NRC inspectors since the original concerns were identified , in IE Inspection Report No.-50-460/78-08,-50-513/78-08. The contractor improved his procedures and achieved satisfactory practices for storing and handling the liner plate. The stainless steel liner plate for both units is now installed and this item is closed.
c.
(0 pen) Followup Item (50-46(/79-02/12): Control of changes ' in equipment. quality classi* 1 cation.
Interim changes have been made to the licensee's governing procedure for control of changes to equipment quality classifi- ' cation (Quality Assurance ~ Procedure No. 3, entitled " Quality Assurance Classifications", revision 3).
Licensee representatives stated that the final version of the revised guidance would be approved by the end of May 1980.
It was also reported that there were no changes in equipment quality classification since the concern was originally identified. This item will be examined after issuance of the final procedures.
d.
(Closed) Followup Item (50-460/79-05/01): Underdesigned supports-for Atlas Industrial letdown coolers (50.55(e) item).
, The licersee's. action in response to the deficiencies in the - letdown cooler supports was reported to the NRC by WPPSS letter No' G01-79-286 of May 7, 1979 and was previously discussed in . , i IE' Inspection Report No.' 50-460/79-05.
During the current inspection , the inspector verified that-the supports had been rebuilt in ' accerdance.with the approved redesign.
It was also determined , that redesign of the sliding supports was not necessary. The i new supports have~been. located in place but not permanently installed..The inspector has no further questions on this item at this time.
<
, f - . - . -. ,-- -,..- ---- -. -,-. - - - .--.-, -
-3- . (Closed)tbncompkiance(50-460/78-02/04): Inadequate e.
document controls.
The licensee's system for controlling documents used in the field was examined during previous inspections (see IE Inspection Report-Nos. 50-460/78-06, 78-07, 79-07, and 79-08). While the control of drawings was found satisfactory, a question existed regarding the cor. trol of one contractor's procedures (J. A. Jones Construction Company).
Examination of this area du.ing the current inspection established that the contractor had implemented additional actions to assure the most current version of the procedures are in the field. These actions included the use of a summary sheet for each document which identifies the current revision for each page of the document. The inspector examined 74 procedures and verified that each was current.
The inspector has no further questions on this item at Jos time.
f.
(0 pen) Followup Item (50-460/79-01/01): Disposition of shear studs which were welded to structural members through metal decking and are now embedded in concrete.
In January 1979, NRC inspectors expressed concern about the disposition of installed shear s tds which were welded to structural members through metd decking, and were now buried in concrete. The welds of studs installed in this fashion were found to exhibit a relatively high failure rate. The engineering analysis of this problem is addressed in a UE&C report entitled " Investigation of Studs", dated May 1,1980.
The report concludes that the integrity of the structures and systems having shear studs welded through metal decking is not adversely affected.
A copy of this report was obtained for review by the NRC.
Accordingly, this item remains open pending completion of that review.
g.
(Closed) Detiation (50-460/79-06/02): Lack of fusion in field fat'ricated floor drain system pipe weld.
a Tti licensee's response tc'the deviation is Smmarized in WPPSS leuter No. G01-79-415 of July 19, 1979. The corrective actions identified in the letter included repair of the deficient weld, and additional training of involved personnel. The inspector verified that these actions were completed and also examined ten welds of similar configuration.
All welds were satisfactory This item is closed.
h.
(Closed) Noncompliance (50-460/79-07/01); Inadequate procedures for control of the calibration of measuring and test equipment.
The licensee's response to the item of noncompliance is summarized in WPPSS letter No. G01-79-471 of August 28, 1979. The letter stated that the governing procedure (P0P-N-704W) has been revised and that an additional document (Inspection-Test-Instruction No. ITI-013) had been developed to assure adequate prccedural direction for the control and calibration of measuring and test equipment.
The inspector examined revision 3 of P0P-N-704W . -. . . .
4- . . . . and revision 1 of ITI-013 to verify inclusion of specification and PSAR requirements in this area.
In addition, the inspector verified that control and calibration was properly accomplished for an oxygen analy7.er, two micrometers, one pressure gage, and a caliper, including environmental control of the calibration room. All items were found to be satisfactory; this item is closed.
i.
(0 pen) Noncompliance (50-460/79-02/05): Procurement documents (contact specifications.) do not contain or reference the applicable PSAR requirements concerning measures for controlling measuring and test equipment.
The licensee's response to the Notice of Violation was summarized in WPPSS letter No. G01-79-297 of May 9,1979, as discussed in IE Inspection Report No. 50-460/79-07. The letter indicated that the specific contractor procedures had been revised (see paragraph h, above) and that procurement documents would be revised to include reference to the applicable requirements in the PSAR.
During the current inspection it was determined that the procurement documents had not been revised.
Discussions with licensee representatives indicated that this action may not be necessary.
Accordingly, during the exit interview at the conclusion of this inspection, the inspector requested that a revised response to the Notice of Violation be provided which accurately identifies the action the licensee intends to take in this area. This item remains open pending NRC's receipt and review of the revised response.
j.
(Closed) Unresolved Item (50-460/79-09/02): Welder performance qualification record not available for review: The licensee and contractor were unable te locate a performance qualification record for welder number A-5 in the 6G position (inclined fixed pipe).
Existing records indicated that the welder had never been qualified for the 6G position but had been qualified for those positions in which he had welded.
The inspector has no further questions on this item.
k.
(0 pen) Unresolved Item (50-460/79-14/03): Weldolet appears to be attached to piping with insufficient weldment.
The licensee has issued Field Change Notice No. 257-1-80-057 to build up the apparently deficient weld area. The doc : ment, howe /or, does not provide criteria for the amount of weldment to be added, i.e. how much buildup should be accomplished.
During the current inspection licensee representatives were unable to specifically identify the amount of weldment to be added. Also, information had not been developed on whether the original weld was inadequate and, if so, what was the cause of the deficiency and , ! whether or not more than the one weld is involved.
This matter continues to be unresolved pending the development of . further information.
-. - _ _
~ -5- . . . . 1.
(0 pen) Followup Item (50-460/80-05/01): Contractor's (J. A.-Jones) nonconformance reports indicate a large number of inspection hold points-have been improperly by-passed.
The 1icensee has issued a Corrective Action Request No.1-CAR-257-10 . requiring acticn to eliminate the continuing problem of by-passing inspection hold points. While the contractor had not officially.
repli ed.to the CAR as of the current inspection,it was found that instructions had been issued to field personnel directing impn.vement in this. area (J. A. Jones Inter-office correspondence from J. J. Flannery to All Field Supervision, dated April 4,1980).
A review of all contractor nonconformance reports (NCR) for the month of April: identified only 1 of 82 NCR's involving the.
) by-passing of hold points, indicating some improvement over the previous three month period where 33 of 228 NCR's involved by-passed hold points. This item will remain open pending review of the contractor's reply to the CAR.
m.
(00en) Followup Item (50-460/80-05/02): Contractor's (J. A. Jones) use of " Request for Information" (RFI) Forms for documentin,g, nonconforming conditions and directing accomplishment of work.
Licensee representatives stated that.RFI's will be revieseo and a nonconformance report issued for each case where nonconforming conditions were identified and not properly documented. This item will be further examined upon completion of the licensee review.
3.
Site Tour On April 29, 1980 the inspectors conducted a tour of both units to observe general construction activities, completed work, equipment storage and the general state of housekeeping. The following adverse housekeeping conditions were noted: . '
. Unit No. 1 , At the J. A. ' Jones laydown yard the inspector identified spool l a.
No..BRS-C106-84-51 which had both ends uncapped and spool No..DHR-415-040-55 which had one end uncapped and contained a quantity of rain water. Both of-these were stainless steel pipe spools. The' contractor's procedure, P0P-N-405W, " Storage, Handling'and Issuance of Items" states in paragraph 6.l.2,. " Protective coverings, end caps and other protective devices will be utilized ! 'and maintained".
l b.
The bowl of reactor coolant pump No. PlA2 contained the following l j debris: A newspaper,' cigarette package, papercup, a doughnut and bag.
l c.
.At the 455' elevation of.the General Service Building near - . column G5 the. inspectors examined a tarp covering stainless ) steel pipe spools and valves and noted that the tarp surface in contact
with the pipe spools was unacceptably dirty. The. inspectors observed ' other pipe spools and valves covered with debris from concrete. work; caps were off some valves and spools and valves were piled'on top of each'other.- l
. l .
-6- . . . . A surveillance report / contractor notification report (SR/CNCR) No. 726 identified the same problem in the same area on fiarch 17, 1980.
This SR/CNCR stated these conditions would be corrected by April 4, 1980.
Unit No. 4 d.
At the 399' elevation of the General Service Building the space heaters were not energized in the electric motors of the following equipment: make-up system pump units MUS-PMP-1A, MUS-PMP-2B, MUS-PMP-3C; containment spray system pump units CS-PMP-1A, CS-PMP-2B; and decay heat removal pump units DHR-PMP-1A, and DHR-PMP-2B.
J. A. Jones procedure JAJ-Wl-005, Revision 2E, " Preventative Maintencnce of Equipment", states in paragraph 6.3,'" Space heaters for equipment set in place shall be energized within two (2) days after equipment is installed". This equipment had been in place for approximately three weeks.
e.
In addition, the flanges of pump MUS-PMP-1A were uncovered and uncapped contrary to the requirements in paragraph 5.8 of J. A. Jones procedure JAJ-Wl-005.
These items were brought to the attention of the licensee on April 29, 1980. On May 1, 1980 the inspectors conducted a tour of the same general area and found the heaters energized for the MVS pumps but not for the CS and DHR pumps. A nonconformance report (4-NCR-257-03) was immediately issued by the licensee to effect corrective action.
The licensee stated that the housekeeping and equipment preservation and the other items identified by the NRC inspectors are continuing problems which the licensee has identified and documented in numerous surveillance reports.
It appears from the results of this and past inspections (see IE Inspection Report Nos. 50-460/79-10,-11,-12,- ' 14, and 80-03) that the measures established to preclude recurrence of equipment cleaniness and pres ~ervation problems have been ineffective.
The failure to properly store.and preserve safaty related equipment ~ is an apparent item of noncompliance with Criterion XIII, Handling, StorageandShipping(50-460/513/80-06/01).
4.
Pipe Sup 7rts and Restraint Systems Werk by Contractor (J. A. Jones Constructicn Company) ' a.
Revicw of Ouality Assurance Implementing Procedures The J. A. Jones work procedures pertaining to safety related , pipe support and restraint systems were examined for compliance to the PSAR, project specifications, and applicable code requirements. The following procedures ware examined: (1) JAJ-WI-010.0, Revision l A, " Hanger Installation Non-ASME III".
(2). JAJ-WI-010.2, Revision l A, "Non-ASME Small Bore Hanger Fabrication".
r ' -7- , . . (3) JAJ-WI-010.1, Revision l A, "ASME III Hanger Installation".
(4) JAJ-N0E-008, Revision 5, " Visual Weld Inspection".
No items of noncompliance or deviations were identified.
b.
Observations of Work and Work Activities The J. A. Jones activities related to pipe support fabrication and installation were examined. This included observations of completed supports for evidence of proper welding, material sizes, configuration conformance, bolt tightening and locking, and location. A total of five quality class I fixed pipe supports were examined, these were: MUS-118-RG-103; CCW-54-SH-108; DHR-15-SG-20; DHR-15-SG-19; and CSS-14-SG-16.
Each of the supports had been inspected, accepted and tagged with an orange adhesive tag (signifies further work not permitted without notifying Project Engineering and QA) by the contractor's quality verification inspectors. Three of the supports were found to be consistent with design and installation procedural requirements. However, supports DHR-15-SG-19 and DHR-15-SG-20 were found to have the U-bolts loose.
Contractor and licensee representatives speculated that the U-bolts were probably loosened after the supports had received the final quality inspection. However, the contractor's project engineering office and QA office had not been notified of the loosening of the hanger U-bolts. This is an apparent item of noncompliance with the requirements of criterion V of 10 CFR 50, Appendix B (50-460/80-06/02).
c.
Review of Quality Records The inspector examined the quality records associated with the five pipe supports identified above. These records included the engineering drawings, hanger inspection checklists, hanger NDE/ weld records, and applicable field change notices and requests for information forms. The~ documents were examined for compliance to appropriate PSAR, project specification, and code requirements.
No items of noncompliance or deviations were identified.
5.
Diesel Generators a.
Observation of Work and Work Activities The inspector examined work activities associated with the placing and installation of the Unit No.1 diesel generators.
This examination consisted of asuertaining whether the requirements of the applicable specifications, work and inspection procedures were being accomplished in the areas of; receipt inspection, storage control, installation, protection and inspection.
The inspector noted that the licensee had identified a number of welding deficiencies with the diesel generator piping early in 1979 and had shipped most of the piping back to the manufacturer (DeLaval) for repair. This piping is now onsite and the contractor has initiated a rework program (FCN No. 257-1-79-834) to conolete the installation of the diesel generator .. _ _ - _.
r-8- . . ' This apparent equipment deficiency has not been reported to the NRC. The reportability concern is considered to be an unresolved item pending development of additional information on this matter during a subsequent NRC inspection (50-460/80-06-03).
b.
Review of Quality Records The quality records associated with the diesel generators were reviewed to ascertain whether the records confirm that receipt inspection, material certifications and installation records were in conformance with established procedures, specifications, and licensee connitments.
The inspector noted the following during his review: (1) Installation Control Records Insta11etion process control sheets indicated that the torque multiplier (Serial No. E) used to tighten the diesel generator hold-down bolts did not have a J. A. Jones Measuring and Test Equipment (M&TE) number or a J. A. Jones calibration sticker. This was documented on contractor nonconformance report No. 1-CNCR-257-372.
(2) Receipt Inspection Records Material and equipment were not readily identifiable per the packing lists. The numbers on the packing lists and the equipment identification numbers did not match.
J. A. Jones has conditionally accepted all these materials.
Equipment has been moved into the buildings and installed that was not properly received.
Several items tagged with " Awaiting Inspection" tags were removed from the UE&C storage area and installed in the buildings.
These items are documented on J. A. Jones nonconformance report No. 1-CNCR-2572753.
(3) Record Packages The data report (form NPP-1) in record packages Nos. 02717-02-CJ, 02-717-02-CK and 02-717-02-DH state that work was accomplished per the 1974 edition of the ASME code thru Winter 1975 addenda.
This conflicts with the related piping drawings which document that the applicable code addenda is thru Summer 1974.
The rework inspection report for package No. 02-717-02-CK indicates that arc strikes, undercut, and undersize fillet welds _wcre to be repaired, yet the liquid penetrant report indicates that only the arc strikes were examined after repair.
These items are considered to be unresolved and will be examined further in a subsequent inspection.
(50-460/80-06/04) i ~ - . ..
,
_- -9- . .. ' . . . 6.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs Sa and b of this report.
7.
Exit Interview The inspectors n.9t wi',h licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on May 2,1980 and summarized the scope and findings of the inspection as stated in this report.
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Washington Public Power Supply System S r. 3~h e k.
A JOINT OPERATING AGENCY y$ p h ..
P O. Son 968 3000 Gao WasMINGF08s W A V RfCMLamp WA9MsesGrose 99 35 2 e(509) 000 August 13, 1980 ' G01-80-225 Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza - 1990 florth California Boulevard Walnut Creek, California 94596 s Attention: Mr. R. H. Engelken, Director Gentlemen: Subject: WPPSS NUCLEAR PROJECTS N05.1 AND 4 NRC IflSPECTION - WNP-1/4 DATES OF INSPECTION - APRIL 29 - MAY 2,1980 DOCKET NOS. 50-460 AND 50-513 CONSTRUCTION PERMIT NUS. CPPR-134 AND -174 Reference: Letter from R. H. Engelken to N. O. Strand, NRC Inspection at WNP-1/4 Site, dated July 11, 1980.
The reference letter provided the results of the April 29 - May 2, 1980 inspection of activities authorized by NRC Construction Permits Nos.
CPPR-134 and -174.
Further, the reference correspondence identified that :ertain activities were not conducted in full compliance with requirements, as indicated in the Notice of Violation enclosed as ' Appendix A.
These items of noncompliance have been categorized into a level as described in your correspondence to all NRC licensees dated December 31, 1974.
In addition, in Appendix B you expressed concern about ineffective corrective actions.
This letter is transmitted in response to the reference correspondence.
The specific NRC Violation / Finding, as identified, and the Supply System response is provided herewith as Appendix A and B, respectively.
Should you have any questions concerning this response, we will be glad to discuss them with you.
Very truly yours, ch' W '*w v, quo R. L. Ferguson, ManagindDirector vh Enclosures (2) ' cc: JR Lewis - BPA CR Bryant - BPA.
V Mani - UE&C, Phil.
GS Spencer - Chief Reactor Construction and Engineering Support Branch
. _ . _ 's . c
e . , APPENDIX A Nuclear Regulatory Commission Region V Suite' 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596 Docket Hos. 50-460 and 50-513 Construction Permit Nos. CPPR-134 and -174 > NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of April 29 - May 2,1980, it appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below: A.
10 CFR 50, Appendix B, Criterion V, as implemented by Sec. tion 17.1.5 of the quality assurance program documented in the PSAR and the WPPSS QA Program Manual Procedure QAP-2, Paragraph 3.1, states in part that, " Activities affecting quality... shall be accomplished in accordance with... instructions, procedures, or drawings."
The hanger inspection checklist of the J. A. Jones Construction Company, the site contractor responsible for installation and inspection of hangers for safety related piping, requires verifi-cation that U-bolt connections are tight. Additionally, J.A. Jones Instruction No. JAJ-WI-010.1, Revision 1A, paragraph 8.7 states . that "'.rter completion of hanger installation, including the documentation required on Hanger. Installation Sketch, the hanger tiill be tagged with an orange adhesive tag, to prevent any further work without notifying Project Engineering and QA.
If additional work is approved, documentation for the work must be provided by .J. A. Jones Engineering."
Contrary to the above, on May 1,- 1980 at Unit 1, pipe hangers Nos. DHR-15-SG-19 and DHR-15-SG-20 supporting safety related . piping had loose U-bolt connections. This nonconforming condition was not id?ntified and the hanger inspection checklists documented that these U-bolt connections had-been inspected and found acceptable. Orange ' adhesive tags were applied to the hangers and no documentation demonstrated that additional work on the hangers subsequent to the inspection and tagging had been approved.
This > is an infraction.
. I J TM-' A
. . . . . . . - s -
. _ _. . ~ . .. o . .. Appendix A Page 2 - SUPPLY SYSTEM RESPONSE Corrective Action Taken and Results Achieved The U-bolt connections on the affected pipe supports were inspected and found acceptable by the contractor's QV on January 11, 1980.
Subsequent construction activities necessitated the removal of the U-bolt connection to adjust the related piping assembly. The contractor's personnel failed to follow their procedures which require documenting construction activities which modify a previously acceptable installation.
' Surveillance Report #848 on Contract #257 documented a check of five (5) pipe.
' supports which had been p.eliminarily accepted by JA Jones QV. Three (3) of the five (5) had loose or missing U-bolts. JA Jones was notified by CNR of this ~ condi tion. CNCR's 'were generated to correct the conditions (1-CNCR-257-938, 939 and 940). The Engineer dispositioned the CNCR's " rework" to retighten or install bolts and generate supplemental documentation for the rework. The reinspection of the CNCR's will document the acceptability of the rework.
Corrective Action-Taken to Preclude Recurrence The contractor will place additional emphasis on this activity by conducting training sessions to reiterate the requirements for performance of additional ' work on hangers and the issuance of proper documentation for activities which have received preliminary acceptance and now require subsequent' supplemental inspection to verify the additional work performed.
It should be noted that preliminary acceptance does not relieve the inspector of assuring that the support meets all of the installation / inspection criteria at the time of final acceptance.
- Paragrapn 4.5.5 of JA Jones I1struction ITI-005, Rev. 2A; " Inspection Instructions for Hangers, Supports and Restraints" states:
"4.E.5 When all inspections have been performed and all documentation is complete and accurate, the Quality Verification Inspector shall sign and date-for "QV Acceptance".
4. 5. 5.1' The inspector shall then place an orange " Preliminary ~ Acceptance" tag on the support indicating that the support is acceptable on that date.
, 4.5.5.2 Final. inspection of the support will be performed prior to system test.~ Preliminary. acceptance does not relieve the inspector,of assuring.that the support meets all the installation / inspection criteria at the time of that acceptance."
, Project Quality Assurance will increase surveillance of this activity to identify any trends or similar conditions. Further action such as Corrective Action Requests and/or work stoppage will be.taken as necessary.
,
r- ' Appendix A ~ ' Page 3 . . Date of Full Comoliance The rework end subsequent reinspection of the U-bolt connections will be delayed until resolution of the existing labor dispute.
' flotice of Violation B.
10 CFR 50, Appendix B, Criterion XIII as implemented oy Section 17.1.13 of the quality assurance program documented in the PSV nu the WPPSS QA Program f4anual Procedure QAP-16, Paragraph 4.1, states in part that "fleasures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment... to prevent damage or deterioration".
Paraaraoh 6.1.2 of procedure P0P-N-405W of the J. A. Jones Construction Comoany, a site contractor resoonsible for construction activities involving safety related piping and components, st- :es that for. piping and ccmponents, " Protective covering,-end caps and other protective services will be utilized and maintained." Further, paragraph 5.3 of J. A. Jones procedure JAJ-Wl-005, Revision 2E, states that, " Space heaters-for equipment set in place shall be energized within two (2) days after equipment is installed."
Contrary to the above, on April 29, 1980: 1.
At the J. A. Jones laydown yard for Unit 1 piping, safety related stainlees steel pipe s?ool ilo. DHR-416-040-55 had one end uncapped and contained a quantity of water, and safety related stainless steel pipe spool fio. BRS-C106-84-51 had both ends uncapped.
2.
The bowl of Unit 1 reactor coolant pump No. Pl A2, a safety related component, was uncovered.and the bowl contained debris including food, newspaper and paper products.
3.
At the 455' elevation of the Unit 1 General Services Building, several uncovered. safety related stainless steel pipe spools and valves for Unit 1 were temporarily stored without protective caps installed and were ccvered with dirt from concreting work.
4.
At the 399' elevation of the Unit 4 General Services Building, space heaters were not energized in the safety related electric motors of three make-up system pump units, two containment spray punp units and two decay heat removal pump units.
5.
The flanges of Unit 4 make-up system pump I40S-P!4P-1A, a safety related component, were open and no protective coNring or protective caps were-installed.
This is an infraction.
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, . . . . ... -- , . e .. Appendix A , , ! Page 4 SUPPLY SSSTEM RESPONSE Corrective Action Taken and Results Achieved Item 1: Surveillance report 818 (Contract 257), dated 5/5/80, to JA Jones identified the-fact that pipe caps were missing. JA Jones responded to the report-stating that'the condition would be corrected by 5/8/80.
Reinspection by the QAE on 5/14/80 indicated that the condition had been corrected and the storage conditiors were acceptable.
Item 2: Surveillance report 252 (Contract 211) -dated 5/5/80, checked all four - -(4) reactor coolant pump bowls for cleanliness and preservation attributes. Conditions at that time were acceptable for all four (4) pumos indicating that the conditions identified by the Inspector had been corrected. A follow-up surveillance was performed on 5/30/80 (report 272) and was also satisfactory.
Item 3: Surveillance, report 852 (Contract 257) was generated on 5/27/80. All , _ pipe checked was properly capped.
Pump bases on elevations 395', 399',
421' and 455' were free of any debris.
Conditions observad were acceptable.
Iten 4: 1-NCR-257-03 was generated on 5/1/80 as a result of this condition.
The disposition on 5/7/80 required J. A. Jones to inspect the pump motors following energization of space heaters and megger test the motors.
Results are to be forwarded to Owner's PM Coordinator.
The disposition- . action and. closure is pending return of craft personnel. The space heaters have been energized and "hard-wired" to the equipmeat.
Item 5: Surveillance report 19 (Unit 4, Contract 257) was generated on 5/1/80.
. One hundred percent (100%) of the Contract 257 equipment in the Unit 4 ' GSB was surveilled.
Deficiencies in the areas of cleanliness and protective-covering were noted. JA Jones was. notified by CNR of the conditions and responded that corrective action would be completed by 5/12/80. A reinspection of the conditions on 6/19/80 showed the work to be complete and conditions acceptable. The CNR was closed.
Corrective Action Taken to Preclude Recurrence - Actions to preclude recurrence'of problems of this nature are outlined in our t response. to ' item.C -of Appendix B of this report.
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'o - APPEMOIX B . . Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596 Docket Nos. 50-460 and 50-513 Construction Permit Nos. CPPR-134 and -174 FINDINGS REGARDING INEFFECTIVE CORRECTIVE ACTIONS The results of an NRC inspection conducted during the period April 29 - May 2, 1980 included findings wherefrom it appears that certain of your corrective actions taken on identified quality problems were ineffective and failed to meet your commitments to the NRC as indicated below: A.
In February 1979, the NRC inspector identified that your diesel-generator contractor failed to fulfill a specification require-ment to designate the quality class on equipment drawings.
In your response of May 9,1979, to this office, you indicated that the quality class designation assures proper identification of equipment and actions had been taken to correct the omission.
During our review of this matter in June 1979 (reference: IE Insoection Report No. 50-460/79-09) we brought to your attention that the omission had not been corrected. As of April 29, 1980 this problem remained uncorrected although your diesel-generator contractor subnitted several equipment drawings to your after May 4, 1979 without the quality designation and these drawings were then issued by WPPSS.
SUPPLY SYSTEM RESPONSE The effectiveness of corrective actions relative to the resolution of Quality Class designation on equipment drawings is recognized, however, mitigating circumstances are extended for your evaluation. Our initial response of May 9, 1979 indicated that actions had been taken to correct the omission. A letter was sent to the diesel-generator contractor and instructions issued to Project Engineers and Design Supervisors to check the quality class designation on all documents prior to issue. Your Inspection Report Nos. 50-460/79-08 and 50-513/79-07 confirmed that we had in fact completed the actions indicated in our response.
On several occasions, vendor surveillance representatives from both United Engineers and Constructors and the Supply System have verbally requested during their visits to the manufacturer's facility that the resubmittal of drawings be accomplished in an expeditious manner. A series of escalated actions culminatina in withholding payment were necessary to close out this item.
At the time of the initial inspection, fabrication of the diesel generators was complete and installation work was in progress, we believe this impacted the contractor's sense of urgency.
Immediately after your April 29, 1980 inspection, all drawings were resubmitted denoting the proper WPPSS quality class designation. Your inspection of July 15-18, 1980 verified and closed this item.
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, - -- _ - --- _ 'n - l Appendix B Page 2 . Findings Regarding Ineffective Corrective Actions B.
In February 1979, the NRC inspector identified that your procurement documents to a contractor did not include or reference those measures - delineated in the PSAR which you committed to use for controlling measuring and test equipment.. In your response of May 9, 1979, to 'this office, you stated that the contractor procurement documents would be revised.
During ouc review of this matter in June 1979 . (reference: IE Inspection Report No. 50-460/79-07), we brought to your attention that the procurement documents had not yet been revised. As of April 29, 1980, these documents-still had not been revised. Your representatives then stated that revisions may not be necessary. However, we understand that a change in your commitment has not yet been authorized nor has a' change been submitted to this office for review.
SUPPLY SYSTEM RESPONSE We acknowledge that our perfc rmance in resolving this finding has not been totally satisfactory. We have completad our review of the PSAR requirements, procurement documents, regulatory requ.rements and ANSI Standards and concluded that the procurement document should be revised to include or reference those measures delineated in the PSAR. We anticipate that the procurement document will be revised and issued to the contractor by September 15, 1980.
It should be noted that the inspection item 50-460/79-07/01 identified a condition where inadequate procedures for control of the calibration of measuring and test equipment was not in accordance with PSAR requirements in this area.
It is further noted that your. inspection report No. 50-460/80-06 and 50-513/80-06 verified that revision 3 of P0P-N-704W and revision 1 of ITI-013 included specification and PSAR requirements in this area.
In addition, your report indicated that the control and calibration of selected calibration equipment and environmental control was found to be satisfactory. This item is closed.
Findings Regarding Ineffective Corrective Actions C.
For the-past nine months various cleanliness and preservation probicas with safety related equipment at the site have been noted by'NRC inspectors (reference: IE Inspection Reports. 50-460/79-10, -11.-12,-14 and 80-03).
Such problems were similarly identified and documented in numerous surveillance reports by your site QA/QC ' inspection staff.
Despite identification of these continuing problems, the actions 'taken to correct their cause and preclude recurrence have been ineffective as demonstrated by our findings during our recent
s i te: in spection. Their findings included fi've instances where the cleanliness and preservation of safety related comnonents were compro-mised bytthe inactions of your site piping installation contractor.
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Appencix B Page 3 , SUPPLY SYSTEM RESPO!1SE Actions to control the cleanliness and preservation of safety related components have escalated since the identification of this item. The contractor was informed that the Supply System considered housekeeping a serious problem.
The contractor created a single point of contact to resolve unsatisfactory conditions in a timely manner. A single point of contact for each area of the project has also beer. established within the construction management organization to assure adequate response to identified deficiencies. Addi-tionally, Project Quality Assurance has initiated a program of systematic surveillance of installed safety related components on a weekly basis to ensure that housekeeping and equipment preservation measures are being implemented.
Essentially, this prcgram consists of identifying the component installed by elevation, building, or zone and verifying that the component is being properly ma i nta 'ned. Deficiencies related to general housekeeping / cleanliness are reported directly to Construction Management or preventative maintenance personnel for corrective action.
Repetitive conditions are identified to the contractor through corrective action requasts and other escalated enforcement actions, as applicable.
W3 wish to reiterate that with the area manager concept, and single point of contact, as well as direct control of preventive maintenance by the Preventive Maintenance Coordinator, and our continuing surveillance of installed equipment, improvement in this area will be apparent and measurable.
As noted by the ilRC inspector at the exit interview on July 18, 1980, considerable improvement in housekeeping and protection of equipment has been achieved.
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I 13 3') Docket i!os. 50 a60 50-513 ' . ' .. l' WashingtonPublicPowerSupplySystem , P. O. Box 968,. s , Richland, Washington 99352 - s , Attention: P.r. R. L. Fercusan ifanagino Director Gentlemen: Thank you for your letter of August 13, 1980. informing us of the steps you have taken to correct the items which we brougnt to your attention in our ' letter dated Vuly 11, 1980. liowever, we find that we require further information on the following two items.
1.
Resconse to Ihm A of f;otice of Violation The response indicates t.ia a nigh percentage (i.e., 3 of 5) of pipe supports caecked by Surveilknce Report #848 had loose or missing U-bolts, but does not identify any action to increase the sample size to establish or refute a basis for generic concern.
2.
Resconse to Fiadiaqs Regarding Ineffective Corrective Actions The response ganerally verifies the long time differential existing between the identification of a prob. lcm situation and the resolution of that problem. The response, however, does not address any future . actions to be taken by the Supply System to assure that effective and timely corrective actions will be taken and/or verified.
This information should be submitted to this office within twenty (20) days of the datc of ?.his letter.
Your cooperation with us is appreciated.
Sincerely, ./ N m G. S. Spencer, Chief Reactor Construction and - Engineering Support Branch j - .#... ___ . _. _. .. .. _.... _. _.... _.. _. , t
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P 'n rg s P, W shingt n Public Power Supply System es-gyG A JOINT OPERATING AGENCY LN 9 gC% lC [[ g g , o. so.... sooo a.o. w..-moro w., a,c u-o w........ . 3sa e oo September 18, 1980 G01-80-264 Nuclear Regulatory Commission , Region V Suite 202, Walnut Creek Plaza ' 1990 North California Boulevard Walnut Creek, California 94596 Attention: Mr. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch Gentlemen: Subject: WPPSS NUCLEAR PROJECTS NOS. 1 AND 4 NRC INSPECTION - WNP-1/4 DATES OF INSPECTION - APRIL 29 - MAY 2, 1980 DOCKET NOS. 50-460 AND 50-513 CONSTRUCTION-PERMIT NOS. CPPR-134 AND - 174 References: 1) Letter from G.S. Spencer to R.L. Ferguson, dated September 4, 1980.
2) Letter from R.L. Ferguson to R.H. Engelken, NRC Inspection - WNP-1/4 Site, dated August 13, 1980 (G01-80-225).
The reference 1) letter required further information with respect to the Supply System response contained in the reference 2) letter.
Attachment A to this letter is the additional Supply System response to your Notice of-Violation and to Findings Regarding Ineffective Corrective Actions, respectively.
Should you have any further questions concerning this response, we will be glad to discuss them with you.
Very truly yours, M D. L. Renberger Assistaat Director, Technology yh Attachment cc: JR Lewis - BPA CR Bryant - BPA V. Mani - UE&C, Phil.
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f ' ~ .,, ATTACHMENT A ., . Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596 Docket Nos. 50-460 and 50-513 Construction Permit Nos. CPPR-134 and -174 1.
Response to Item A of Notice of Violation ' The response indicates that a high percentage (i.e., 3 of 5) of pipe supports checked by Surveillance Report #848 had loose or missing U-bolts, but does not identify any action to increase the sample size to establish or refute a basis for generic concern.
Additional Supply System Response The relatively small sample size of pipe supports identified in reference 2) that were selected for reinspection was predicated on the fact that only five (5) of the pipe supports installed to date, with preliminary accept status, contained U-bolts.
On September 11, 1980, an inspection of all accessible pipe supports containing U-bolts was performed by Project Quality Assurance. The inspection was performed to determine if the installed condition, inspec-tion status and support of documentation were consistent with procedural requirements. Fifty-nine (59) of the accessible pipe supports contained U-bolts. Only two (2) of the fifty-nine (59) supports contained the preliminary acceptance tag and the remaining fif ty-seven (57) were still considered in-process. The JAJ inspection record check point for torquing of the two (2) preliminary accepted supports had been signed and accepted by JAJ QV. The documentation for the remaining fifty-seven (57) supports indicated no QV acceptance. A verification of the installed condition confirmed the compliance to the procedural requirement.
Based on the results contained in Surveillance Report #913 dated September 11,1980, 't is our position that the condition identified in your letter is an is H case and not a basis for generic concern.
2.
Response to Findings Regarding Ineffective Corrective Actions The response generally verifies the long time differential existing between the identification of a problem situation and the resolution j of that problem. The response, however, does not address any future actions to be taken by the Supply System to assure that effective and timely corrective actions will be taken and/or verifie __ ___s . ., .i ' , b . . , 1 Attachment A ' Page 2 , Additional Supply System Response The previous system of tracking NRC items was not effective for the standard of performance anticipated by WPPSS management and the NRC.
To improve our performance regarding ineffective corrective actions, we recently implemented a change to assign the responsibility to influence and emphasize the need to resolve NRC-items q,uickly and effectively at the Project Managers level through a managenent system entitled: " Managing Project Level Action Requirements". To accomplish the imple-mentation of this new approach, Project Quality Assurance will coordinate the tracking of the Action Item / Critical Item and pro <ide the results on an as-required basis to the Project Manager for his review with the responsible departraent.
Effective August 25, 1980 a new Planning / Measurements group became a functional and integral part of the WNP-1/4 QA department. This group will be staffed by Project Quality Assurance Specialists with various backgrounds' and expertise. The principle functions of this group will entail detailed reviews of contractor performance for detection of trends, assessment and overview of the adequacy of contractor inspection effec-tiveness. _This group will also coordinate project level action require-ments as they apply to Project Quality Assurance with particular emphasis on Regulatory itens.
Performance standards for compliance and effective-ness of surveillance / audit programs will be developed to suit WPPSS Corporate policies.
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WALNUT CREEK, CALIFORNI A 94596 Y 9 i.?SO - . . Docket Nos. 50-460 50-513 s Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 ' Attention: Mr. R. L. Ferguson Managing Director Gentlemen: Thank you for your letter dated September 18, 1980 informing us of the additional-steps you have taken to correct the items which we brought to your attention in our letter dated July ll,1980. Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely, Y;) fanu~ .. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch .
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