IR 05000508/1980010
| ML20003G715 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 10/20/1980 |
| From: | Elin J, Haist D, Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20003G631 | List: |
| References | |
| 50-508-80-10, 50-509-80-10, NUDOCS 8104300583 | |
| Download: ML20003G715 (10) | |
Text
{{#Wiki_filter:* . O.
- - U. S. ::CCLEAR RECUL\\ TORY C010!ISSIO:t ' OFFICZ OF INSFECTION AND ENFORCEME!."r " 50-50S/80-10 50-509/80-10 Report :*o.
, 50-508 & 50-509 CPPR-154 & 155 ticen3, 30, Safeguards Group Docket No.
Washington Public Power Supply Systen Licensee: P. O. Box 968 ' Richland, liashington 99352 Wi!P-3 and WilP-5 Facility Name: Ut P-3 and !!TlP-5 Site (Satsop) Ir.spection at: Inspectiqn conducted: Fentember 23-26, 1980 Inspectors: / [ d N- /t[20[70 ' D. P. Ha M t, Reactor Inspector Date Signed
/ ,' /df*Lf) d ' gd.'0. Elin, Reactor Inspector Date' Signed
_ Date Signed ~ [ 's h Approved By:
- v *~ - --
- /6/ 2/s.
- R. C. Haynes, CITT37, Projects Section Date Signed Reactor Construction and Engineering Support Branch Su ary: Inspection durino the ceriod of September 23-26, 1980, (Report flos. 50-508/S0-10 and 50-509/80-10) Areas Insnected: Routine, unannounced inspection by regional based inspectors of construction activities including storage, handling, protection and receipt of safety related components; licensee action on previous inspection findings; licensee action on IE Bulletins; and ouality assurance program and implementing procedures of the prine electrical contractor. The inspection involved 49 inspector-hours onsite by two f!RC inspectors.
Results: One item of noncompliance applicable to both units was identified in the area of final location storage of Quality Class 1 equipment.
RV Form 219 (2)
.. - - -- ... - - - _ -. - .- . -. . . , . . . ! DETAILS 1.
Persons Contacted a.
Washincton Public Power Sunniv System (UPPSS) ,
- C. E. Love, Deputy Division Manager
- J. C. Lockhart, Ouality Assurance Manager
- R. A. Davis, Senior Project Quality Engineer
- 0. E. Trapp, Project Engineering Manaaer
- M. ii. Monopoli, Ouality Assurance Staff Engineer
- J. J. Terestra, Contract Administrative Supervisor
- E. L. Stephens, Assistant Civil Superintendent
- J. A. Vanni, Project Quality Engineer
l b.
EBASCOServices,Inc.(EBASC01 ,
- A. M. Cutrona, Decuty Quality' Assurance Manager
- L. A. Bast, Project Ouality Engineer j
- L. F. Adans, Senior Project Ouality Engineer
-
- J. C. Purphy, Project Superintendent
.
- T. E. Cottrell, Senior Resident Engineer l
J. Uerle, Senior Design Engineer K. A. Kirkevold, Engineer ~ '
c.
Peter V.ewit Sons' Comoany O. Paulson, QA fianager i d.
Hallace/Suoerior (US)
i R. UcGuire, QA itanager G. Stein, QC Manager e.
State of Uashinoton (EPIEC)
- G. Hansen, Senior Projects Engineer
- Denotes those persons present at the exit interview on September 26, 1980.
2.
Site Tour r, On September 23, 1980, the inspectors conducted a tour of Units 3 and 5 to observe completed work and work in progress for obvious deviations or i noncompliance with PSAR commitments and regulatory requirements.
Particular i attention was given to the activities of safety related component storage conditions, structural steel welding and structural bolting, and concrete placement activities.
. . - . . _... _. _. ~, _ _. _ _ _ _ _ _ _ _ _ _.. _ _ _ _ _ _
- - . .- - . . .. -2- . . . The inspectors identified an apparent item of noncompliance in the
storage conditions associated with charging pumps installed in their final location in Units 3 and 5.
Three charging pumps in Unit 5 and one charqing pump in Unit 3 were stored in conditions not meeting the analicable. equirements of ANSI N45.2.2 and Regulatory Guide 1.38.
(These items are detailed in Paragraph 5.d.-) 3.
Licensee Action on Previousiv Identified Followup Items.
a.
(Onen) 50-508/80-07/01 Wallace/Sucerior-Control of Weld Filler Ma terial. During a previous inspection, 31 pieces of unused E60ll, 3/32-incn weld filler raterial were found to be uncontrolled during the Unit 3 plant tour.
The inspectors found no uncontrolled weld filler material during this inspection. The inspector examined Wallace/Sut erior Procedure No. OCP-7-7 Pevision 2 for control of weld filler metal.
No deviations from the reouirements of AWS 01.1 were identified. The certifications and test data for tvo heats of E70S-3 weld filler metal and one heat of E7018 weld filler metal were examined against - AUS D.l.1 and Procedure OCP-7-7 requirements.
No items of noncompliance
' or deviations were identified.
The weld filler metal control system will be examined in the context of the entire Wallace/ Superior quality assurance program and specification and PSAR requirements during a subsequent inspection.
t b.
(Coen) 50-508/80-07/02 Wallace/Sucerior-Use of Contractor NCR Form- ! Procecure OCP-12-12.
During a previous inspection the inspector observed that the Wallace/ Superior nonconformance reporting Procecure No. OCP-12-12 did not specifically address the use of the contractor's NCR form for onsite detected nonconformances.
During this inspection, the inspector reiterated the concern to the
licensee that without specific guidance, the contractor NCR form
could be used to disposition nonconformances where engineer review l is required pursuant to criterion III of 10 CFR 50 Appendix B.
The contractor has committed to provide specific guidance on the use of the Wallace/ Superior NCR form. This item remains ' open.
4.
Licensee Actions on IE Bulletins ( ' a.
Dulletin 78-12, 73-12A and 78-12B - Atypical Held Material in Reactor Vessel uelds The licensee response letter No. G03-80-531, dated March 17, 1980 l indicated that a generic report entitled " Atypical Weld Material in Reactor Vessel Welds" by Combustion Engineering, was submitted to the URC on June 8, 1979. The inspector examined the site copy of the report which indicated that there is no evidence of atypical weld raterial in the WHP-3 or 5 reactor vessels. This item is closed.
, ' l l i i i '
. - . -3- . . , b.
Bulletin 79-02, Revision 2-Pioe Suonort Desions Usino Concrete . Exnansion Anchor Bolts.
The licensee response letter dated December 13, 1979 reiterated a previous response which indicated that there are no plans to use concrete expansion anchors for attachment of Seismic Class I pipe supports at UNP-3/5. This iten is closed.
c.
Bulletin 79-03A-Lonqitudinal Weld Defects in Stainless Steel Pipe Scoois.
The licensee letter No. G03-80-795 dated April 15, 1980 in response to Bulletin 79-03 indicated that an inspection program on the UNP-3 gas stripper regenerative heat exchanger shell disclosed no evidence of centerline lack of penetration. The letter also stated that the inspection program was not applicable to the WNP-5 gas stripper heat exchanger shell because, althouoh it uses the same material specification, it is fren a different manufacturer, Trent Tube Division of Colt Industries.
. Bulletin 79-03A stated that the problem of centerline lack of penetration is generic to all welded SA-312/A312 material, and that the NRC has verified centerline lack of penetration in SA-312 or A312 fusion welded pipe manufactured by the Trent Tube Division.
The licensee was unaware of any expansion of the inspection program to cover the WNP-5 gas stripper shell as a result of Bulletin 79-03A.
The licensee committed to investigate the action to be taken in light of the above.
Licensee letter No. G03-80-1910 dated August 8, 1980, addressed
specifically to Dulletin 79-03A, stated that a review of piping naterial was in progress to determine if any SA-312 or A-312 Type 304 fusion welded pipe is in use or planned for use on WHP-3/5. The results of this review are not yet available. This item remains open.
d.
Bulletin 79-10-Deen Draft Pumo Deficiencies The licensee response letter No. G03-79-1871 dated October 3, 1979 stated that the only pumps falling into the design class described in the subject bulletin are the containment spray pumps. The l inspector exanined the following records associated with the subject pumps: (1) Drawings, sectional assemblies and parts list; (2) Quality assurance requirements (in the form o' a manufacturing and quality control plan); and (3) design specifications. The licensee was not aware of any reliability testing requirements or procedures used to align the pump column.
In addition, specific instructions to verify the absence of the bulletin-identified deficiencies during inspections . were not included in the specifications or manufacturing and quality control plan.
Since the pumps have not yet been manufactured, no maintenance history is available, no major repair efforts have been undertaken and tests have not been performed. The licensee committed to investigate the bulletin requirements stated above. This item remains open.
. - . -. - - - - - - . .. - . . - - - -. - -. - - - - - . - . - - - - - - . - - - - -. . - .. . - - - - - - . -. - - - - - . - -
-4- - . . . .
e.
Bulletin 79-24 - Frozen Lines This bulletin was issued for information to the licensee.
At the request of the inspector, the licensee replied to the bulletin in letter G03-80-2294, dated September 22, 1980. A review by the licensee of safety-related process, instrument, and sampling line freeze protection indicates that the design of the category IE electric freeze protection and maintenance systems imooses sufficient criteria to ensure that thernal alam sensors are: (1) located to monitor.
the anticipaged worst case condition and (2) calibrated to indicate within +2/-0 F of the actual fluid temperature. This item is closed.
f.
Bulletin 80-05 - Vacuum Condition Resulting in Damage to Chemical Volume Control System Holdup Tanks The licensee response letter flo. ELE-GCS-80-176 indicated that all tanks in the chemical and volume control system are adequately protected. The licensee is presently reviewing the design of all tanks ' and components in the radwaste system. The results of this review are expected to be available on October 12, 1980. This item remains open.
g.
Bulletin 80-08-Examination of Containment Liner Penetration Welds Licensee response letter flo. G03-80-1732 dated July 15, 1980 states that 1005 radiography will be performed on the butt welds at the WitP-3/5 containment penetration connections. Where radiography is not practical or results of radiography are inconclusive, ultrasonic exanination will be perfomed. The weld joint will be a butt weld with a consumable insert. Specifications governing this work do not pemit use of a backing ring. This item is closed.
h.
Bulletin 80-09-Hydramotor Actuator Deficiencies Licensee response letter flo. G03-80-1521 dated June 25, 1980 indicated that hydramotor actuators of the specified models are being supplied to WilP-3/5 under tuo contracts.
Licensee letter flo. G03-80-2291 dated September 22,19P,0 indicated that American Warming and Ventilating Company ( AWV) is supplying twenty-eight ITT-General Control's actuators with a t'o.1 spring for use in danper actuating applications.
AWV will compare the results of ITT-GC testing with their damper torque requirements for acceptability. Valtek Inc. is also awaiting the results of the ITT-GC test program prior to confirming that their actuators are adequately sized. This item remains open.
i.
Bulletin 30-10-Contamination of flon-Radioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to - Environment This bulletin was issued to holders of construction permits for information. The licensee has forwarded this bulletin to his Architect-Engineer for infomation and use. This item is closed.
-i- ,
. . j.
Pol' otin Sn-16-Potential MisaDnlication of Rosemount Inc. Models 115' and 1152 Pressure Transmitters with Either "A" or "D" Output Codes Licensee rernonse letter No. ELE-KAH-80-014 dated August 19, 1980 indicates t no Rosemount f'odel 1151 or 1152 pressure transmitters with outs codes "A" or "D" are installed or planned to be installed in safety-rel e d applications at WflP-3/5. This item is closed.
e
k.
BulleF ' 80-19-Failures of Percury-Wetted liatrix Relays in Reactor Prc
- ave Systems of Operatino fluclear Power Plants Designed by Combustion Enoineering Licensee rescon3e letter flo. G03-30-2124 dated September 5, l'.'80 indicates that fiodel HG2X-10ll mercury wetted relays, or other mercury wetted relays are not used in the logic matrix of the reactor protection system at WNP-3/5. This item is closed.
5.
Review of Safety Pelated Eauipment Storace.
a.
Review of Procedures (EBASCO/WPPSS) The inspector examined the following EBASC0/WPPSS procedures detailing receipt inspection, storage, and maintenance of material and equipment: QAI 10-1 Receiving inspection and material requisitioning.
QAI 13-1 Surveillance of storage / maintenance functions for project procured permanent plant material , and equipment.
> ASP-0A-7-12 Use of quality status tags.
ASP-0A-7-6 Receiving inspection.
ASP-0A-7-7 Quality assurance records.
. ASP-Aft-8-2 Program and management for the maintenance of equipment and material during storage.
ASP-Aft-3-5 ftaterial control.
. ASP-RE-2-23 Standard requirements for maintenance of equipment and materials during storage.
The inspector found that these procedures did reflect, in general, the requirements of AftSI fl45.2.2 and AflSI N45.2.3 for receiving, storage, maintenance and housekeeping.
a - - ,-, -- -,., - ,, -,,.,,, , - - -, - -,,, - -, ~ - , - - , -, - - -.- -.-
- . -6- . . . b.
Review of procedures (Fischbach-f4 core) ' The inspector reviewed several Fischbach-!4 core procedures detailing receiving inspection, storage and control of measuring and test
ecuipment.
In addition, the Fischbach-f4 core Quality Assurance f4anual was reviewed.
The Fischbach-floore Quality Assurance f4anual appeared to be a general document applicable to several construction sites.
It did not contain specific instructions as to applicable standards at the UtlP 3/5 site. These specific references to applicable standards were to be detailed in instructions or procedures preDared for the il!!P 3/5 site. The Quality Assurance f4anual appeared to reet the requirements of a quality assurance program in accordance with 10 CFR 50, Appendix B.
The Fischbach-fiocre receiving inspection instruction (QAP-30153) which had been accroved by WPPSS/EBASCO, was examined for comoliance with " AflSI ti45.2.2. This procedure did not appear to provide detailed ' instructions to the receiving inspector in accordance with Af!SI :i45.2.2.
Specifically, the standard was only mentioned in the tabulated reference section (paragraph 3.2).
The specific inscection steps detailed in Af4SI f145.2.2, paragraph 5.2.2, were not referenced or ra-stated in the procedure. Also, the receiving inspection chec) list provided did not require all the inspection criteria detailed in the standard.
The instruction in paragraph 5.1.6(B) required that " Receiving ' inspection shall be performed in an area equivalent to the level of storage recuirement for the item (s) being inspected." The instruction did not provide any details as to what the " Levels of Storage" were or what requirements were to be imposed, or provide ' reference to this information.
The instruction in paragraph 5.1.5(A) stated "in some cases, it may not be possible to determine the proper storage requirements prior to receipt of an item." flo instructions were provided as to what to do in this case. The receipt inspector's responsibilities and actions were not clear if this situation did arise.
The inspector expressed concern that this instruction did not provide specific guidance to the receiving inspector in accordance with AflSI 1145.2.2. The licensee stated that this instruction would be reviewed further and appropriate changes made.
Fischbach-icore Instruction C/QCP-30253 " Electrical !!aterial arJ Equipment Storage and Cont.ol" was also reviewed. The inspect)r noted that this procedure, in paragraph 6.2.15 did not require ' segregation or barriers, in addition to hold tags, to be provide i for nonconforming naterial in accordance with Af4SI f145.2.2 an' applicable ilPPSS/EBASCO procedures. The licensee stated that this would be changed to conform with requirements. These procedures will be examined during a subsequent inspection.
(50-508/80-10/01) (50-509/80-10/01) ' . - - . . - -. - .. - - .. - - --.- - - _- -
7_ . , . . . - Fischbach-Moore Procedure QAP-40153 " Control of Measuring and-Test Equipment" was reviewed.
This instruction did not provide detailed instructions for calibration and control of test equipment , at the site. The procedure stated that "The project engineer or , his designee" was to prepare a " Project procedure to inplement ! the calibration and control program..*". It further required that " Detailed project procedures shall be prepared and approved ' to provide the following: (a) Calibration procedures and instructions for the equipment and tools to be calibrated onsite.
(b) Care, maintenance and control of the calibration reference standards."
These detailed project procedures were not approved by EBASC0/WPPSS at the time of the inspection and were not reviewed by the ., inspector, c,. Insoection of Work and Work Activities The inspector toured the EBASC0/WPPSS warehouses onsite and the Saginaw laydown area for compliance with the requirements of Regulatory Guide 1.33/ ANSI M45.2.2, Regulatory Guide 1.39/ ANSI N45.2.3 and
EBASC0/UPPSS instructions. Two receiving inspectors and a maintenance manager were interviewed.
The inscector found that storage conditions for Level A, B, and C components met or exceeded requirements. The inspector determined that EBASC0/UPPSS receiving inspectors had been adequately instructed in receiving inspection requirements as detailed in paragraph 5.2.2 of ANSI M45.2.2.
The inspector noted that safety injection tanks at the Saginaw Laydown Area had mass growing on their outer surfaces. This moss appeared to be removable by wiping the affected areas. The licensee stated that these tank surfaces would be cleaned. The inspector also identified several embed plates with hold tags which were not segregated by rope barriers in accordance with procedures. Many other embed plates > were located nearby with hold tags and properly segregated. The ' licensee stated that segregation ropes would be provided.
The inspector noted that the laydown area was prone to weed growth.
The licensee stated that chemical sprays are used for weed abatement.
The inspector cautioned the licensee about use of chemical sprays near sensitive components such as stainless steel pipe.
During this inspection the only stainless steel materials were found in level B warehouses so that there was no problem then.
i i e u . .. m . . . . . . . . . -- - - - . - . . - . . . -.. - - . - . .
. - - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - -8- - . . . . . d.
Review of Final Location Storace During the site tour on September 23, 1980 and at several other times during the inspection, the inspector examined final location storage conditions of safety related equipment.
The inspector observed that Unit 3 reciprocating charging pump 2 and Unit 5 reciprocating charging pumps 1, 2, and 3, which had been placed on foundation mounts, were not being maintained in storage conditions that meet the requirements of Regulatory Guide 1.38 and ANSI N45.2.2.
The pumps (level C items) and their associated motors (level B items) were covered with a wood frame structure. This structure was covered and enclosed, except at the floor, by visquene sheets. The floor is concrete. Heating and temperature control was provided by three incandescent lights at the motor end of the enclosure.
The inspector noted that the floor of the pump room, both inside and outside the visauene enclosure, was covered with approximately 1 inch of water. This storage condition was contrary to the requirements - of the ANSI N45.2.2 standard.
Peter Kiewit Sons' Company Procedure No. PKS-WI-A101, " Care and Maintenance Inspection for Charging Pumps", defines s'torage to be ANSI N45.2.2 storage level B for the motors and level C for the pumps.
Section 6.1.2 of the ANSI standard states that the storage area shall be well drained.
In this case, the floor drains had been plugged which permitted water to accumulate on the floors. No alternate means had been provided to avoid the accumulation of water.
The failure to maintain the floor in a well drained condition neqated the storage objective to maintain the eqJipment dry.
The heat source provided by the licensee in the form of incandescent-lights within the visquene enclosure tended to heat the enclosed water and increase the water vapor content within the enclosure.
This additional water vapor was then free to condense back to liquid form on the cooler surfaces of the motor or pump.
Thus, the storage condition provided by the licensee was not fully effective in minimizing moisture within the equipment as intended.
The inspector observed these pumps daily during the inspection and the conditions identified above persisted until the morning of September 26, 1980. The licensee believed that the storage conditions were adequate. Storage of quality class 1 charging pumps at Unit 3 have been the subject of previous NRC finding (IE Insoection Report
- o. 50-503/79-10).
Charging pump maintenance records were reviewed by the inspector.
These records showed that the specific maintenance requirements detailed by Peter Kewit Sons' Company procedure were being met, however, this procedure did not include the "well drained floor" requirements of ANSI N45.2.2.
Nonetheless, contract specification No. 3240-251, entitled " Erection of Piping Systems and Installation of Mechanical Equipment", applicable to the quality affecting activities performed by the Peter Kewit Sons' Company at WNP-315, invokes the requirements of ANSI N45.2.2-1972 for the receiving, handling and storage of all materials.
_ _ , _ _ -. . - .- .- - - _. - . -. - ,. .
.- . -9- , , . o . The failure of the storage procedure'to establish adequate measures to - . maintain final location storage conditions for reciprocating charging pumps within the standards' invoked by the contract specification is an apparent item of noncompliance (50-508/80-10/02) (50-509/80-10/02).
, . The inspector observed that quality class 1 reactor building drain ' pumps installed in Unit 3 were stored in a similar manner to the charging pumps noted above. There was again some evidence of ' moisture present within the enclosing structure.
The environmental conditions of storage of these and other quality class 1 equipment items will be within the scope of future inspection efforts pertaining ' to the above item of noncompliance.
l 6.
Management Meeting . The inspectors, including the resident reactor inspector, met with the : licensee representatives, denoted in paragraph 1 at the conclusion of the inspection on September 26, 1980. The insoectors summarized the scope of ! the. inspection and the findinas. The licensee was informed that as a result of the recent Systematic Assessment of Licensee Performance (SALP)
of WilP-3/5, more attention will be focused by the inspectors on the adequacy of procedures and preplanning efforts prior to the start of .; ' safety related activities.
!
! .
i n l
T p Kiry *
- UNITED STATES 4, 8i ( % NUCLEAR REGULATORY COMMISSION
.' E
REGION V
, I
1990 N. CALIFORNIA BOULEVARD 'o SUITE 202, WALNUT CREEK PLAZA , og,,* WALNUT CREEK, CALIFORNIA 94596 APR 13 G81 Docket Nos. 50-508 50-509 , Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 Attention: Mr. D. E. Dobson WNP-3/5ProgramDirector(Acting) Gentlecen: Thank you for your letter dated March 13, 1981 informing us of the additional steps you have taken to correct the items which we brought to your attention in our letter dated October 21, 1980. Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely, 7.7. aAa-B. H.
aulkenberry hief Reactor Constructi ects Branch - l
r
. .., ' #*AY% P N P W shington Public Fower Supply System t a , A JOINT OPERATING AGENCY Q .% > -s& P. O. 8041223 E LM A. W ASHINGTON 98541 249 5001 March 13,1981 G03-81-746 Nuclear Regulatory Commission, Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596 Attention: Mr. B. H. F.'J1kenberry, Chief Reactor Construction Projects Branch Gentlemen: Subject: WPPSS NUCLEAR PROJECTS 3 & 5 NRC INSPECTION OF WNP-3 and WNP-5 00CKET NUMBERS 50-508 AND 50-509 Referem e: 1). Letter, R.H. Engelken to R.L. Ferguson, NRC Inspection at Washington Nuclear Projects Nos. 3 and 5, dated October 21, 1980.
2).
G03-80-2965, letter, F.D. McElwee to G.S. Spencer, same subject, dated November 21, 1980.
3). Letter, to F.D. McElwee, same subject, dated November 6, 1981.
Reference 3 presented questions reg 6rding incorporation of ANSI equipment storage requirements into Contractor procedures. Answers provided herein will attempt to clarify the actions taken at the WNP-3/5 site.
' l.
As indicated in IE Inspection Report No. 50-508, 509/80-10 which l accompanied the subject Notice of Violation, site records showed l that the charging pump storage requirements detailed by Peter Kiewit Sons' procedure were being met. However, this procedure failed to establish adequate measures to maintain final location storage conditions within the standards invoked by the contract specifications; namely the ANSI N45.2.2-1972 standard. What specific actions have adequately incorporated the specific storage requirements of ANSI N45.2.2-1972? l l Storage conditions specified by the Charging Pump Manufacturer can be l met by conformance with ANSI N45.2.2-1972 Level C.
Motor storage re-i quires the additional controls of energized Strip Heaters and a pro-l tective cover with an internal heat source.
l l 91-M ,
. . ' Washington Public Power Supply System Mr. B. H. Faulkenberry March 13,1981 Page 2 G03-81-746 Engineering assessment of the Charging Pump Rooms, has determined the manufacturer's storage requirements can be met without imposing Level B ANSI requirements. Consequently, the Engineer will initiate a Field Change Request (FCR) which aligns the Contract with actual manufacturer storage recomendations.
These storage requirements are applicable only to the pump pedestal upon which the Charging Pump and motor are stored.
Peter Kiewit Sons' Co. will be directed to incorporate these specific re-quirements into their Care and Maintenance Instructions.
The date of full compliance for these actions will be implemented by April 15, 1981.
2. What specific actions have been taken, or will be taken, to ensure that other contractors responsible for the storage and maintenance of Quality Class I equipment have procedures which incorporate the requirements of industry standards invoked by the contract specification? Contracts, other than 3240-251, which require care and maintenance of Quality Class I equipment are 225/253 and 232. The 225/253 Contractor's quality assurance program specifies, in accordance with contract require-ments, procedures which govern the preparation and implementation of Care and Maintenance Instructions (CMI's).
Contract requirements spe -ify re-ferencing manufacturer's recomendations for storage and maintenance, Engineer's CMI's are reviewed and approved by the Engineer to ensure that these requirements are incorporated in the CMI's. The 232 contractor has comitted (letter 232WP-81-012 dated January 29, 1981) to utilize a proce-dure governing the preparation of CMI's. This procedure, 3240-232-100 (" Preparation of Care and Maintenance Instructions") is expected to be implemented by May 1,1981 pending review and approval by the Engineer as described above.
I Should you have any questions or desire further information, please feel free to contact me directly.
Very truly yours, M D. E. D0BSON Acting Program Director, WNP-3/5 cc: D. Smithpeter - BPA Ebasco - New York WNP-3/5 Files - Richland I
. . , -
. , . . . D. E. DOBSON, Being first duly sworn, deposes and says: That he is the Acting Program Director, WNP-3/5, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authorized to submit the foregoing on behalf of said applicant; that he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge.
DATED 3 e I3 , 1981.
% D. E. DOBSON
STATE OF WASHINGTON )) ss
COUNTY OF GRAYS HARBOR) On this day personally appeared before me D. E. D0BSON to me known to be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and purposes therein mentioned.
GIVEN under my hand and seal this /3' day of Qcu tb , 1981.
, kuu w NotaryPubfcinandfohtheState of Washington Residing at -d. [ atts
' . PP W shington Public Power Supply System A JOINT OPERATING AGENCY
P. O 8011223 E L M A, W A%HINGTON 98541 PHONE (206] 249-5001 February 20, 1981 G03-81-531 Nuclear Regulatory Commission, Region V Suite 202, Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California 94596 Attention: Mr. G. Chief, Reactor Construction and Engineering Support Branch Gentl emen: Su bject: WPPSS NUCLEAR PROJECTS 3 AND 5 NRC INSPECTION OF WNP-3 AND WNP-5 DOCKET NUMBERS 50-508 AND 50-509 References: 1) Letter, R. H. Engelken to R. L. Ferguson, NRC Inspection at Washinton Nuclear Projects Nos. 3 and 5 dated, October 21, 1980.
2) Letter, G. to F. D. Elwee, same subject, dated November 6, 1980.
JA8 fd '# ! 3) Letter, G. to F. D. Elwee, same subject, dated January 6,1981.
The NRC requested information relative to incorporation of ANSI requirements into contractor storage procedures in reference 3.
These responses will not be completed by the requested date, due to the complexities of the involved conditions.
We request the response dates be delayed until March 13, 1981.
If this does not meet with your approval, please so indicate as quickly as possible.
Very truly yours, _ _ D. E. DOBSON Project Manager, WNP-3/5 -
cc: D. Smithpeter - BPA g@ Ebasco - New York N y[[8 WNP-3/5 - Richland O 2, m ,
_.
sMuctiq#o, =
, UNITED STATES [h ~"g NUCL' EAR REGULATORY COMMISSION .\\ <
REGION V
. ej - d1 ' g# 1990 N. CALIFORNIA BOULEVARD ' ' ' g * YJ e SulTE 202, WALNUT CREEK PLAZA
- ,,,e WALNUT CR EE K, CAllFORNI A 94596 FEB Yo 1981-Docket Nos. 50-508 50-509
. Washington Public Power Supply System P. O. Box 968 . Richland, Washington 99352 Attention: Mr. D. E. Dobson Acting Program Director Gentlemen: Subject: Request for delay in response date, (your letter of January 29,1981).
Thank you for your letter, referenced above, requesting a delay in the response date for four letters iss'ued by G. S. Spencer, Region V, to F. D. McElwee, dated January 5, 6, and 9 1981. Extension of the
response date to February 20, 1981, as requested, is acceptable to this office.
Sincerely, &_ R. H. Engelken Director . f/03)s0028
Y h $rt E@$ $1 . .
P e gG y g~ Washington Public Power Supply System A JOINT OPERATING AGENCY $ $
' _ P. O 8011223 ELM A, W ASHINGTON 98541 PHONE [206] 2i9-5001 January 29, 1981 G03-81-264 fluclear Regulatory Commission, Region V Suite 202, Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California 94596 . Attention: Mr. R. H. Engelken Gentlemen: Subject: WPPSS NUCLEAR PROJECTS 3 AND 5 DOCKET NOS. 50-508, 50-509 References: 1) Letter, G. to F. D. McElwee, dated January 5,1981, regarding response - to August 29 - Septembe,r 26, 1980 inspection.
2) Letter, G. to F. D. McElwee, dated January 6,1981, regarding response' to September 23-26, 1980 inspection.
3) Letter, G. to F. D. McElwee, " November 18-21, 1980 Inspection," - dated January 9, 1981.
4) Letter, G. to F. D. McElwee, , " December 8-19, 1980 Inspection," dated January 9, 1981.
The NRC has requested in the referenced four (4) letters various responses or information from the Washington Public Power Supply System. However, we will not be able to complete our effort by the dates requested in your letters.
This is due to the large quantity of information being generated by several site organiza-tions and contractors.
The additional time is required to verify that the information is complete and accurate, prior to stating commitments to the NRC.
We request that our response date for the four (4) letters be delayed until February 20, 1981. We trust this delay will be acceptable to you.
Very truly yours, W - D. E. DOBSON Acting Program Director, WNP-3/5 cc: D. Smithpeter - BPA Ebasco - New York WNP-3/5 Files - Richland A'pt8/03Xoo.A:9-- f/-d J
'o ' UNITED STATES
[Dg' g'.k
NUCLdAR REGULATORY COMMISS ON j
REGION V
g g.fuJ g 1G90 N. CALIFORNIA BOULEVARD D %. * O ,o SUITE 202, WALNUT CREEK PLAZA
- ,,*
WALNUT tREEM, CALIFORNIA 94596 jius ! n,': Docket tios. 50-508, 50-509 Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 , Attention: Mr. F. D. McElwee !IllP-3/5 Program Director References: (1) WPPSS Letter from F. D. McElwee to G. dated Hovemoer 21, 1980,tio. G03-80-2965 (2) !!RC Letter from G. to R. L. Ferguson dated October 21,1980 Gentlemen: . Thank you for your letter, Reference (1), responding to the item of noncompliance provided to you by Reference (2). Cur review of the information presented in your letter indicates that there iaay oe a misunderstanding concerning the cause of the item of noncompliance. Coasequently, we neeo additional information to permit our assessment of your corrective actions. Accordingly, pursuant to Section 2.201 of the ilRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, you are required to submit to this office, within twenty-five (25) days of the date of this letter, a written statement or explanation addressing the following questions regarding the finding and the incorporation of AfiSI equipment storage requirements into contractor procedures.
1.
As indicated in IE Inspection Report !!o. 50-508, 509/80-10 which accompanied the subject f!atice of Violation, site records showed that the charging pump storage requirements detailed by Peter Kiewit Sons' precedure were being met. However, this procedure failed to establish adequate measures to maintain final location storage conditions within the standards invoked by the contract specification; namely, the AflSI fl45.2.2-1972 standard. Ilhat specific actions have been taken to ensure that the Peter Kiewit Sons' maintenance procedure adequately incorporates the specific storene requirements of ~ AflSI fl45.2.2-1972? 2.
What specific actions have been taken, or will be taken, to ensure that other contractors responsible for the storage and maintenance of Quality P00R ORBNAl.
. - . -.
,,, - - . . . . . - . , , I Washington Public Power-2-j,p; y% Supply System ' - Class 1 equipment have procedures which adequately incorporate the specific requirements of industry standards invoked by the contract specification? Please contact us if you have any questions regarding the above. Your cooperation is appreciated.
Sincarely, bLL-G. S. Soencer, Chief ! P.eactor Construction and Engineering Support Branch cc: M. E. Witherspoon, Division Manager Quality Assurance, WPPSS D. E. Dobson, Division Manager WNP-3/5,WPPSS P00R BNgyz ?rdi4 t&- 'm --e+-e+e - t-T-* ,mf,. p a y---P
- r
- e -- w - m - , - - - e M eF-- en< c-mF* & em ? w
- ~
. V. g y . m?%7 - - - . - , ,. . PP W shington Public Power Supply System
- 1 $
'g $
Q,. o)Bg A JOINT OPERATING AGENCY
Y s P. O. BOX 1221 E LM A, W ASHINGTON 98541 PHO%t l206] 249-5001 November 21, 1980 G03-80-2965 Nuclear Regulatory Comission, Region V Suite 202, Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California 94596 Attention: Mr. G. Chief Reactor Construction and Engineering Support Branch Subject: WPPSS NUCLEAR PROJECTS 3 & 5 NRC INSPECTION OF WNP-3 AND WNP-5 DOCKET NUMBERS 50-508 AND 50-509 References: 1) Letter, R. H. Engelken to R. L. Ferguson, NRC Inspection at Washington Nuclear Projects Nos. 3 and 5, dated October 2{,1980.
2) Letter, D. F. Knuth to all AEC Licensees, " Criterion for Determining Enforcement Action and Categories of Noncompliance", dated December 31, 1974.
'
Dear Mr. Spencer:
This letter is in response to your letter of October 2k 1980, which discussed the results of the inspection conducted September 23-26, 1980, of activities authorized by Nuclear Regulatory Commission Construction Permit Numbers CPPR-154 and CPPR-155. The letter identified one item of noncompliance categorized in accordance with Reference 2 and required the Supply System to provide a response to these items.
The specific Nuclear Regulatory Comission Finding, as stated in your letter, and the Supply System respanse are provided in Attachment I to this letter.
Should you have any questions or desire further information, please feel free to contact me directly.
Very truly yours, D.
. Ic L Program Director, WNP-3/5 Attachment cc: D. Smithpeter - BPA Ebasco - New York WNP-3/5 Files - Richland SO M
...- - , c.
- , , ' ATTACHMENT I 10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities , affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances... Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished..." Paragraph 17.1.5 of the Quality Assurance Program documented in the PSAR states, in part, that " Contractors and vendors, including Ebasco and C-E, are required to have written instructions, procedures, policies and/or drawings which govern their quality related activities and , which include appropriate quantitative and qualitative acceptance / , rejection criteria... " Contract Specification No. 3240-251, entitled " Erection of Piping Systems and Installation of Mechanical Equipment", applicable to site work by the Peter Kiewic Sons' Company, states, in part in paragraph 2.8 that, " Receiving, hanuling and storage of all materials shall comply with ANSI N45.2.2-1972. Levels of storage shall be designated by the j engineer..." Appendix 2. A-D to the specification includes a chart in
paragraph 2.2 wherein the engineer designated ANSI N45.2.2 level B as the storage level for the charging punps.
Section 6.1.2 of ANSI N45.2.2-1972 defines storage requirements for level B equipment to include storage in an area that fs "well drained".
Contrary to the above, on September 23, 1980, the Peter Kiewit Sons' Company Procedure No. PKS-WI-A101, entitled " Care and Maintenance Inspection for Charging Pumps", the governing praedure concerning inplace storage of the charging pumps, did not include the appropriate acceptance criteria for a well drained storage area.
Further, the final storage locations for Unit 5 charging pumos Nos. 05-CH-PP-003, 004 and 005 and Unit 3 charging pump No. 03-CH-PP-004 were not well drained in that the floor drains were plugged shut and the floors of ' these areas were covered with water to a depth of one inch during the
period September 23-26, 1980.
This is an infraction (applicable to both Units 3 and 5).
Corrective Steps Which Have Been Taken Directions were issued to the Contractor responsible for general housekeeping ' in the Charging Pump Rooms to remove floor drain plugs and to vacuum any remaining water standing in accumulated areas.
Directions were issued to the Contractor to plug all electrical conduit lines where water was weeping and contributing to this drainage condition.
Drains shall remain plugged until further notice.
Directions were issued to the Contractor to wipe off any accumulated moisture found on charging pump and motor exterior surfaces.
-1- ,_ _ -_ _._.. _ -. _ _ _..,. _ _ _ _ _, _ _ _ _. - .. ~
._ .
- M
. . . Corrective Steps Which Have Been Taken (Continued) Owner / Engineer QA/QC shall verify that the above corrective measures have been completed and the results of these verifications shall be documented by the Owner / Engineer.
Date of full compliance will be December 10, 1980.
Corrective Steps Which Will Be Taken To Avoid Further Violation The deficiency identified is an isolated case caused by Contractors plugging floor drains during clean-up operations to prevent construction debris from " stopping up" drains, and not removing drain plugs in a timely manner.
Contractors working in the plant island have been directed to remove drain plugs in a more timely manner in order to maintain well drained storage areas.
Contractors responsible for the care and maintenance of "in-placed" stored equipment were notified to include draining requirements as a-QA/QC Surveillance or inspection checkpoint, if not presently addressed in their QA program.
If deficient draining conditions are identified in the future, Contractors shall document and resolve these conditions in accordance with his approved QA program.
Date of full compliance will be December 10, 1980.
In addition the Owner / Engineer will reevaluate all currently specified ANSI N45.2.2 storage levels and determine if a lower storage level or a " modified" storage level for equipment stored "in-place" can be assigned.
Where applicable, vendor concurrence shall be received prior to lowering ~ or r-difying current ANSI N45.2.2 storage levels. This effort will be comp red by December 15, 1980.
i t-2- ,_ - ---, -. -., - -. - -. - - -....,. - -.. - -..... - - -. - --. -
YA g . . . e a -. UNITED STATES .
% NUCLEAR REGULATORY COMMISSIO:s y, I
REGION V
[ 1990 N. CALIFORNIA BOULEVARD ,e SulTE 202, WALNUT CREEK PLAZA ogge WAt *duT CRE E K, CALIFORNIA 94506 ' 0CT 21 1930 Cocket flo. 50-508 50-509 cp @ O82 ' Washington Public Power Supply System -- Gg % g% g g [gf f P. O. Box 968
-
Richland, Washington 99352
Attention: Mr. R. L. Ferguson 's / Managing Director q p Gentlemen: Subject: tlRC Inspection at Washington fiuclear Projects fios. 3 and 5 This refers to the inspection conducted by Messrs. D. P. Haist and J. O. Elin of this office on September 23-26, 1980 of activities authorized by flRC Construction Permit flos. CPPR 154 and CPPR 155, and to the discussion of our findings with Mr. C. E. Love and other members of your staff at the conc'"sion of the inspection.
Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, in- _ terviews with personnel, and observations by the inspector.
Based on the results of this inspection, it appears that one of your activities was not conducted in full compliance with f1RC requirements, as set forth in the flotice of Violation, enclosed herewith as Appendix A.
These items of noncompliance has been categorized into a level as de-scribed in our correspondence to all flRC licensees dated December 31, 1974.
This notice is sent to you pursuant to the provisions of Section 2.201, of the flRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office, within thirty (30) days of your receipt of this notice, a written statement or explanation in reply including (1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
- - - . -. . -.
- . _.
- . , ' ' Washington Public Power Supply System-2-OCT 2 L 1980 . In acccrdance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you believe
to be proprietary, it is necessary that you submit a written application to this office, within 30 days of the date of this letter, requesting that such information be withheld from public disclosure. The application musi include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be glad to discuss them with you.
Sincerely, jW G. S. Sp cer, Chief Reactor Construction and Engineering Support Branch Enclosures: A.
Notice of Violation B IE Inspection Report No. 50-508/80-10 50-509/80-10 . cc w/o enclosure B: M. E. Witherspoon, Division Manager Quality Assuiance, WPPSS D. E. Dobson, Division Manager, WPPSS i - - - - - - - - - - - - - - - - - - .-
' - . , . . . APPEf! DIX A . Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352 Docket flumber 50-508, 50-509 ' Construction Permit t' umber CPPR 154, CPPR 155 NOTICE OF VIOLATION Based on the results of flRC inspections conducted on September 23-26, 1980, it appears that one of your activities was not conducted in full compliance with the conditions of your NRC Construction Permit No. CPPR-154/155 as indicated below: 10 CFR 50. Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances... Tnstructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished..." Paragraph 17.1.5 of the Quality Assurance Program documented in the PSAR states, in part, that " Contractors and vendors, including Ebasco and C-E, are required to have written instructions, procedures, policies and/or drawings which govern their quality related activities and which include appropriate quantitative and qualitative acceptance / rejection criteria..." Contract Specification fio. 3240-251, entitled " Erection of Piping Systems and Installation of Mechanical Equipment", applicable to site work by the Peter Kiewit Sons' Company, states, in part in paragraph 2.8 that, " Receiving, handling and storage of all materials shall comply with AilSI I!45.2.2-1972.
Levels of storage shall be designated by the engineer..." Appendix 2. A-D to the specification includes a chart in paragraph 2.2 wherein the engineer designated ANSI N45.2.2 level B as the storage level for the charging pumps.
Section 6.1.2 of AilSI fl45.2.2-1972 defines storage requirements for level B equipment to include storage in an area that is "well drained".
Contrary to the above, on September 23, 1980, the Peter Kiewit Sons' Company Procedure !!o. PKS-WI-A101, entitled " Care and Maintenance Inspection for Charging Pumps", the governing procedure concerning inplace storage of the charging pumps, did not include the appropriate acceptance criteria for a well drained storage area.
Further, the final storage locations for Unit 5 charging pumps flos. 05-CH-PP-003, 004 and 005 and Unit 3 charging pump No. 03-CH-PP-004 were not well drained in that the floor drains were plugged shut and the floors of these areas were covered with '.<ater to a depth of one inch during the period September 23-26, 1980.
This is an infraction (applicable to both Units 3 and 5).
_ ,- _ - _ - _. - _.
. _
. . . . U. S. NUCLEAR REGUL\\ TORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT " 50-508/80-10 50-509/80-10 Report No.
, 50-508 & 50-509 CPPR-154 & 155 License No.
Safeguards Group _ Docket No.
Washington Public Power Supply System Licensee: P. O. Box 968 ' Richland, Washington 99352 WNP-3 and WNP-5 Faci'.ity Name: Wi!P-3 and WNP-5 Site (Satsop) Inspection at: Inspectiqn conducted: Seotember 23-26, 1980 Inspectors: / [ d t/b- /4//0[fo
'D.
P. Ha ' t, ".eactor Inspector Date Signed 0. b. ' ~ /Of21)ffSd [/J.'0. Elin, Reactor Inspector Date' Signed
Date Signed i - --- / 6/ u/ G o Approved Ey: - ' " R. C. Haynes, 'CiiTe?, Projects Section Date Signed Reactor Construction and Engineering Support Branch Su:: mary: Inspection curing the period of September 23-26, 1980 (Reportflos. 50-508/80-10 and 50-509/80-10) Areas Inspected: Routine, unannounced inspection by regional based inspectors of construction activities including storage, handling, protection and receipt of safety related components; licensee action on previous inspection findings; licensee action on IE Bulletins; and ouality assurance program and implementing procedures of the prime electrical contractor. The inspection involved 49 inspector-hours onsite by two NRC inspectors.
Resul ts: One item of noncompliance applicable to both units was identified in tne area of final location storage of Quality Class 1 equipment.
, RV Form 219 (2) .~ _ _ . _ - . - -_.
--, _ -.
. - - - -. - _, - _ -
~ . . . DETAILS 1.
Persons Contacted a.
Washincton Public Power Sunnly System (WPPSS)
- C. E. Love, Deputy Division Manager
.
- J. C. Lockhart, Quality Assurance Manager
- R. A. Davis, Senior Project Quality Engineer
- 0. E. Trapp, Project Engineering Manager
- M.11. l'onopoli, Ouality Assurance Staff Engineer
- J. J. Terpstra, Contract Administrative Supervisor
- E. L. Stephens, Assistant Civil Superintendent
- J. A. Vanni, Project Quality Engineer b.
EBASCO Services, Inc. (EBASCO)
- A. f t. Cutrona, Deputy Ouality Assurance Manager
- L. A. Bast, Project Ouality Engineer
- L. F. Adams, Senior Project Quality Engineer
- i
- J. C. Murphy, Project Superintendent
- T. E. Cottrell, Senior Resident Engineer J. Werle, Senior De51gn Engineer K. A. Kirkevold, Engineer c.
Peter Kewit Sons' Comnany D. Paulson, QA Manager d.
Wallace/Suoerior (WS) R. I'cGuire, QA Manager -
G. Stein, QC Manager e.
State of Washington (EFSEC)
- G. Hansen, Senior Projects Engineer
-
- Denotes those persons present at the exit interview on September 26, 1980.
l 2.
Site Tour On September 23, 1980, the inspectors conducted a tour of Units 3 and 5
to observe completed work and work in progress for obvious deviations or noncompliance with PSAR commitments and regulatory requirements. Particular ! attention was given to the activities of safety related component storage conditions, structural steel welding and structural bolting, and concrete placement activities.
.
-2- . . . The inspectors identified an apparent item of noncompliance in the storage conditions associated with charging pumps installed in their final location in Units 3 and 5.
Three charging pumps in Unit 5 and one charging pump in Unit 3 were stored in conditions not meeting the applicable requirements of ANSI M45.2.2 and Regulatory Guide 1.38.
(These items are detailed in Paragraph 5.dt) 3.
Licensee Action on Previously Identified Followup Items.
, a.
(Ocen) 50-508/80-07/01 Wallace/Sucerior-Control of Weld Filler Material. During a previous inspection, 31 pieces of unused E60ll, 3/32-incn weld filler material were found to be uncontrolled durica the Unit 3 plant tour The inspectors found no uncontrolled weld filler material during this inspection. The inspector examined Wallace/ Superior Procedure No. OCP-7-7 Revision 2 for control of weld filler metal.
No deviations from the requirements of AWS Dl.1 were identified. The certifications and test data for two heats of E705-3 weld filler metal and one heat of E7018 weld filler metal were examined against - AUS D.l.1 and Procedure QCP-7-7 requirements.
No items of noncompliance or deviations were identified.
The weld filler metal control system will be examined in the context of the entire Wallace/ Superior quality assurance program and specification and PSAR requirements during a subsequent inspection.
< b.
(Coen) 50-508/80-07/02 Wallace/ Superior-Use of Contractor NCR Form-Procecure OCP-12-12.
During a previous inspection the inspector observed that the Wallace/ Superior nonconformance reporting Procedure No. OCP-12-12 did not specifically address the use of the contractor's NCR form for onsite detected nonconformances.
During this inspection, the inspector reiterated the concern to the licensee that without specific guidance, the contractor NCR form could be used to disposition nonconformances where er.gineer review is required pursuant to criterion III of 10 CFR 50 Appendix B.
The contractor has committed to provide specific guidance on the use of the Wallace/ Superior NCR form. This item remains open.
4.
Licensee Actions on IE Bulletins ! a.
Bulletin 78-12, 78-12A and 78-12B - Atypical Weld Material in Reactor Vessel Welds The licensee response letter No. G03-80-531, dated March 17, 1980 indicated that a generic report entitled " Atypical Weld Material in Reactor Vessel Welds" by Combustion Engineering, was submitted to the NRC on June 8,1979.
The inspector examined the site copy of the report which indicated that there is no evidence of atypical weld naterial in the WNP-3 or 5 reactor vessels. This item is closed.
. _ _.
- _ _., _ _ - . - -- ~ . - ._. _ - -
-_ _ _ _ _.. -3- , . . b.
Bulletin 79-02, Revision 2-Pioe Supoort Desians Usino Concrete Exoansion Anchor Bolts.
The licensee response letter dated December 13, 1979 reiterated a previous response which indicated that there are no plans to use concrete expansion anchors for attachment of Seismic Class I pipe supports at WNP-3/5. This item is closed.
c.
Bulletin 79-03A-Longitudinal Weld Defects in Stainless Steel Pipe Scools.
The licensee letter flo. G03-80-795 dated April 15, 1980 in response to Bulletin 79-03 indicated that an inspection program on the WNP-3 gas stripper regenerative heat exchanger shell disclosed no evidence of centerline lack of penetration. The letter also stated that the inspection program was not applicable to the WNP-5 gas stripper heat exchanger shell because, although it uses the same material specification, it is from a different manufacturer, Trent Tube Division of Colt Industries.
. Bulletin 79-03A stated that the problem of centerline lack of penetration is generic to all welded SA-312/A312 material, and that the liRC has verified centerline lack of penetration in SA-312 or A312 fusion welded pipe manufactured by the Trent Tube Division.
The licensee was unaware of any expansion of the inspection program to cover the WNP-5 gas stripper shell as a result of Bulletin 79-03A.
The licensee committed to investigate the action to be taken in light of the above.
Licensee letter No. G03-80-1910 dated August 8, 1980, addressed specifically to Bulletin 79-03A, stated that a review of piping material was in progress to determine if any SA-312 or A-312 Type 304 fusion welded pipe is in use or planned for use on WNP-3/5. The results of this review are not yet available. This item remains
open.
d.
Bulletin 79-15-Deep Draft Pumo Deficiencies The licensee response letter No. G03-79-1871 dated October 3, 1979 stated that the only pumps falling into the design class described in the subject bulletin are the containment spray pumps. The inspector examined the following records associated with the subject pumps: (1) Drawings, sectional assemblies and parts list; (2) Quality assurance requirements (in the form of a manufacturing and quality control plan); and (3) design specifications. The licensee was not aware of any reliability testing requirements or procedures used to , align the pump column.
In addition, specific instructions to verify the absence of the bulletin-identified deficiencies during inspections were not included in the specifications or manufacturing and quality control plan.
Since the pumps have not yet been manufactured, no maintenance history is available, no major repair efforts have been undertaken and tests-have not been performed. The licensee committed to investigate the bulletin requirements stated above. This item remains open.
- - . - - - - -
-4- . . . . e.
Bulletin 79-24 - Frozen Lines This bulletin was issued for information to the licensee. At the request of the inspector, the licensee replied to the bulletin in letter G03-80-2294, dated September 22s 1980. A review by the licensee of safety-related crocess, instrument, and sampling line freeze protection indicates that the design of the category IE electric freeze protection and maintenance systems imooses sufficient criteria to ensure that thernal alarn sensors are: (1) located to monitor theanticipagedworstcaseconditionand(2)culibratedtoindicate within +2/-0 F of the actual fluid temperature. This item is closed.
f.
Bulletin 80-05 - Vacuum Condition Resulting in Damage to Chemical , Volume Control System Holduo Tanks The licensee response letter No. ELE-GCS-80-176 indicated that all tanks in the chemical and volume control system are adequately protected. The licensee is presently reviewing the design of all tanks ' and components in the radwaste system. The results af this review are expected to be available on October 12, 1980.
This item remains open.
_ g.
. Bulletin 80-08-Examination of Containment Liner Penetration Welds Licensee response letter No. G03-80-1732 dated July 15, 1980 states that 100% radiography will be performed on the butt welds at the WNP-3/5 containment penetration connections. Where radiography is not practical or results of radiography are inconclusive, ultrasonic examination will be performed. The weld joint will be a butt weld , with a consumable insert. Specifications governing this work do not permit use of a backing ring. This item is closed.
h.
Bulletin 80-09-Hydramotor Actuator Deficiencies - . Licensee response letter No. G03-80-1521 dated June 25, 1980 indicated - that bydramotor actuators of the specified models are being supplied to WNP-3/5 under two contracts.
Licensee letter No. G03-80-2291 dated September 22, 1980 indicated that American Harming and Ventilating Company (ANV) is supplying twenty-eight ITT-General Control's actuators with a Mo.1 spring for use in damper actuating applications.
' AWV will compare the results of ITT-GC testing with their damper torque , i requirements for acceptability. Valtek Inc. is also awaiting the ' results of the ITT-GC test program prior to confirming that their actuators are adequately sized. This item remains open.
i.
Bulletin 89-10-Contamination of Non-Radioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment This bulletin was issued to holders of construction permits for information. The licensee has forwarded this bulletin to his Architect-Engineer for information and use.
This item is closed.
_ _ ... . __
-5- - . . . . . ~ j, nul' etin 80-16-Potential Misapolication of Rosemount Inc. Models 11S' and 11S2 Pressure Transmitters with Either "A" or "0" Output Codes Licensee response letter No. ELE-KAH-80-014 dated August 19, 1980 indicates that no Rosemount Model 1151 or 1152 pressure transmitters with output codes "A" or "D" are installed or planned to be installed in safety-related applications at WNP-3/5. This item is closed.
k.
Bulletin 80-19-Failures of Mercury-Wetted Matrix Relays in Reactor Protective Systems of Operatina Nuclear Power Plants Designed by Combustion Enaineering Licensee response letter No. G03-80-2124 dated September 5, 1980 indicates that Model HG2X-10ll mercury wetted relays, or other mercury wetted. relays are not used in the logic matrix of the reactor protection system at WNP-3/5. This item is closed.
5.
Review of Safety Related Eauipment Storace.
a.
Review of Procedures (EBASC0/WPPSS) The inspector examined the following EBASC0/WPPSS procedures detailing receipt inspection, storage, and maintenance of material and equipment: QAI 10-1 Receiving inspection and material requisitioning.
QAI 13-1 Surveillance of storage / maintenance functions for project procured permanent plant material and equipment.
ASP-QA-7-12 Use of quality status tags.
ASP-QA-7-6 Receiving inspection.
ASP-QA-7-7 Quality assurance records.
ASP-AM-8-2 Program and management for the maintenance of equipment and material during storage.
AS P-AM-3-5 Material control.
AS P-RE-2-28 Standard requirements for maintenance of equipment and materials during storage.
The inspector found that these procedures did reflect, in general, the requirements of ANSI N45.2.2 and ANSI N45.2.3 for receiving, storage, maintenance and housekeeping.
_ . _ _ _ _. _ _. ._ -6- . , - . . b.
Review of Procedures (Fischbach-Moore) ~ The inspector reviewed several Fischbach-Moore procedures' detailing receiving inspection, storage and control of measuring and test equipment.
In addition, the Fischbach-Moore Quality Assurance Manual was reviewed.
The Fischbach-Moore Quality Assurance Manual appeared to be a general document applicable to several construction sites.
It did not contain specific instructions as to applicable standards at the ' UMP 3/5 site. These specific references to applicable standards were to be detailed in instructions or procedures prepared for the WNP 3/5 site. The Quality Assurance Manual appeared to meet the requirements of a quality assurance program in accordance with
10 CFR 50, Appendix B.
The Fischbach-Moore receiving inspection instruction (QAP-30153) which had been approved by WPPSS/EBASCO, was examined for compliance with ANSI M45.2.2.
This procedure did not appear to provide detailed ~ instructions to the receiving inspector in accordance with ANSI M45.2.2.
Specifically, the standard was only mentioned
in the tabulated reference section (paragraph 3.2).
The specific inspection steps detailed in ANSI N45.2.2, paragraph 5.2.2, were not referenced or re-stated in the procedure. Also, the receiving . inspection checklist provided did not require all the inspection criteria detailed in the standard.
The instruction in paragraph 5.1.6(B) required that " Receiving inspection shall be performed in an area equivalent to the level of storage requirement for the item (s) being inspected." The instruction did not provide any details as to what the " Levels of Storage" were or what requirements were to be imposed, or provide reference to this information.
The instruction in paragraph 5.1.5(A) stated "in some cases, it may not be possible to determine the proper storage requirements prior to recaipt of an item." No instructions were provided as to what to do in this case. The receipt inspector's responsibilities and actions were not clear if this situation did arise.
The inspector expressed concern that this instruction did not provide specific guidance to the receiving inspector in accordance with , ANSI M45.2.2.
The licensee stated that this instruction would be reviewed further and appropriate changes made.
Fischbach-Moore Instruction C/QCP-30253 " Electrical Material and Equipment Storage and Control" was also reviewed. The inspector noted that this procedure, in paragraph 6.2.15 did not require segregation or barriers, in addition to hold tags, to be provided for nonconforming material in accordance with ANSI N45.2.2 and
applicable WPPSS/EBASCO procedures. The licensee stated that this ' would be changed to conform with requirements. These procedures will be examined during a subsequent inspection.
(50-508/80-10/01) (50-509/80-10/01) " J
., --.... -., , , .. ,. -.-. -, ,, - -, - ,. -,r-,, - ~, - _ ~ -., .. -, - --.
_ -7-
- . - . . Fischbach-Moore Procedure QAP-40153 " Control of Measuring and Test Equipment" was reviewed.
This instruction did not provide detailed instructions for calibration and control of test equipment at the site. The procedure stated that "The project engineer or his designee" was to prepare a " Project procr. dure to inplement the calibration and control program.. ". It further required that " Detailed project procedures shall be rrepared and approved to provide the following: (a) Calibration procedures and instructions for the equipment and tools to be calibrated onsite.
(b) Care, maintenance and control of the calibration reference standards."
These detailed project procedures were not approved by EBASC0/WPPSS at the time of the inspection and were not reviewed by the inspector.
c.
Insoection of Work and Work Activities The inspector toured the EBASC0/WPPSS warehouses onsite and the Saginaw laydown area for compliance with the requirements of Regulatory Guide 1.38/AtlSI f145.2.2, Regulatory Guide 1.39/AliSI t145.2.3 and EBASC0/WPPSS instructions. Two receiving inspectors and a maintenance manager were interviewed.
The inspector found that storage conditions for Level A, B, and C components met or exceeded requirements. The inspector determined that EBASC0/WPPSS receiving inspectors had been adequately instructed in receiving inspection requirements as detailed in paragraph 5.2.2 of AliSI T145.2.2.
The inspector noted that safety injection tanks at the Saginaw Laydown Area had moss growing on their outer surfaces. This moss appeared to be removable by wiping the affected areas. The licensee stated that these tank surfaces would be cleaned.
The inspector also identified several embed plates with hold tags which were not segregated by rope barriers in accordance with procedures. !!any other embed plates were located nearby with hold tags and properly segregated. The licensee stated that segregation ropes would be provided.
. The inspector noted that the laydown area was prone to weed growth.
The licensee stated that chemical sprays are used for weed abatement.
The inspector cautioned the licensee about use of chemical sprays near sensitive components such as stainless steel pipe.
During- , this inspection the only stainless steel materials were found in level B warehouses so that there was no problem then.
! . - - - - - - - - - - - - - - - - - . - ...
._8 . . . d.
Review of Final Location Storace During the site tour on September 23, 1980 and at several other times during the inspection, the inspector examined final location-storage conditions of safety related equipment.
The inspector observed that Unit 3 reciprocating charging pump 2 and Unit 5 reciprocating charging pumps 1, 2, and 3, which had been placed on foundation mounts, were not being maintained in storage conditions that meet the requirements of Regulatory Guide 1.38 and ANSI N45.2.2. The pumps (level C items) and their associated motors (level B items) were covered with a wood frame structure. This structure was covered and enclosed, except at the floor, by visquene sheets. The floor is concrete. Heating and temperature control was provided by three incandescent lights at the motor end of the enclosure.
The inspector noted that the floor of the. pump room, both inside and outside the visauene enclosure, sas covered with approximately 1 inch of water. This storage condition was contrary to the requirements - of the ANSI fl45.2.2 standard.
Peter Kiewit Sons' Company Procedure No. PKS-WI-A101, " Care and Maintenance Inspection for Charging Pumps", defines storage to be ANSI ?!45.2.2 storage level B for the motors and level C for the pumps. Section 6.1.2 of the ANSI standard states that the storage area shall be well drained.
In this case, the floor drains had been plugged which permitted water to accumulate on the floors. No alternate means had been provided to avoid the accumulation of water.
The failure to maintain the floor in a well drained condition negated the storage objective to maintain the equipment dry. The heat source provided by the licensee in the form of incandescent lights within the visquene enclosure tended to heat the enclosed water and increase the water vapor content within the enclosure.
This additional water vapor was then free to condense back to liquid form on the cooler surfaces of the motor or pump.
Thus, the storage condition provided by the licensee was not fully effective in minimizing moisture within the equipment as intended.
The inspector observed these pumps daily during the inspection and the conditions identified above persisted until the morning of September 26, 1980.
The licensee believed that the storage conditions were adequate. Storage of quality class 1 charging pumps at Unit 3 have been the subject of previous NRC finding (IE Inspection Report flo. 50-503/79-10).
Charging pump maintenance records were reviewed by the inspector.
These records showed that the specific maintenance requirements detailed by Peter Kewit Sons' Company procedure were being met, however, this procedure did not include the "well drained floor" requirements of At!SI fl45.2.2.
Nonetheless, contract specification No. 3240-251, entitled " Erection of Piping Systems and Installation of Mechanical Equipment", applicable to the quality affecting activities performed by the Peter Kewit Sons' Company at WNP-315, invokes the requirements of ANSI N45.2.2-1972 for the receiving, handling and storage of all materials.
-- - - _ _, . - _. _..
-9- - . ,
.. . - . The failure of the storage procedure to establish adequate measures to maintain final location storage conditions for reciprocating charging pumps within the standards invoked by the contract specification is an apparent item of noncompliance (50-508/80-10/02) (50-509/80-10/02).
The inspectre observed that quality class 1 reactor building drain pumps installed in Unit 3 were stored in a similar manner to the charging pumps noted above. There was again some evidence of moisture present within the enclosing structure.
The environmental conditions of storage of these and other quality class 1 equipment items will be within the scope of future inspection efforts pertaining to the above item of noncompliance.
6.
Management Meeting The inspectors, including the resident reactor inspector, met with the licensee representatives, denoted in paragraph 1 at the conclusion of the inspection on September 26, 1980.
The inspectors summarized the scope of the inspection and the findings. The licensee was informed that as a result of the recent Systematic Assessment of Licensee Performance (SALP) of WNP-3/5, more attention will be focused by the inspectors on the adequacy of procedures and preplanning efforts prior to the start of-safety related activities.
, ! ! t l l < _.
. _ _ .. - - _, .,. _ _ _ _ - - _ _ _. _.,. }}