ML17272A451

Responds to NRC 790417 Ltr Re Violations Noted in IE Insp on 790227-28,0301-02 & 14-16.Corrective Actions:Process Instrument Pipe & Other Parts of Reactor Vessel Nozzle Were Taped

ML17272A451
Person / Time
Site:	Columbia
Issue date:	05/10/1979
From:	Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GO2-79-92, NUDOCS 7905190076
Download: ML17272A451 (10)

Text

REGULATORY IN ORMATION DISTRIBUTION SYST (RIDS)

ACCESSION NBR:7905190076 DOC ~ DATE: 79/05/10 NOTARIZED: NO DOCKET 50 397 WPPSS NUCLEAR PROJECTi UNIT 2i WASHINGTON PUBLIC PONE FACIL BYNAME 05000397 AUTH AUTHOR AFFILIATION RENBERGERiD ~ L. WASHINGTON PUBLIC POWER SUPPlY SYSTEM REC IP ~ NAME RECIPIENT AFF ILI AT ION ENGELKENiR ~ H,i REGION 5t SAN FRANCISCOi OFFICE OF THE DIRECTOR

SUBJECT:

RESPONDS TO NRC 790417 LTR RE VIOLATIONS NOTED IN IE INSP ON 7 90227 28 '30 1 02 5 1 4 1 6 ~ CORRECTIVE ACTIONS PROCESS INSTRUMENT PIPE 8 OTHER PARTS OFF REACTOR VESSEL NOZZlE WERE TAPED'ISTRIBUTION CODE: B019S COPIES RECEIVED:LTR t ENCL 1 SIZE TITLE: CONSTRUCTION DEFICIENCY REPORT (10CFR50e55E) ~

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RECIPIENT ID CODE/NAME COPIES LTTR ENCL RECIPIENT ID CODE/NAME

'OPIES

. LTTR ENCL ACTION: 14 PM 7v7 Qyu~Q 1 1 15 BC ~~< W ( 1 1 20 LA Qvur ~g 1 1 ~

21 AD VASSAL@ 1 1 INTERNAL: RE$ 1 1 02 NRC PDR 1 1 05 ISE 2  ? 07 EDO 8 STAFF 1 1 08 MPA 1 1 09 DEPY DIR DPM 1 1 10 QAB 1 1 11 STANDRDS DEV 1 1 12 JORDAN'/IE 1' 13FIELD COOR/IE 1 1 16 AD FOR ENGR 1 1 17 AD PLANT SYS 1 1 17 AD REAC SFTY 1 1 19 AD SYS/PROJ 1 1 22 DIR DPM 1 1 23 OELD 1 1 AD/SITE TECH 1 1 DIRECTOR DSE 1 1 GEOSCIENCES BR 1 1 STRUCT ANLYS BR 1 1 EXTERNAL: 03 LPDR 1 1 04NSIC 1 1 24 ACRS 16 16 RS l3li" TOTAL NUMBER OF COPIES REQUIRED: LTTR 43 ENCL 43

1 Washington Public Power Supply System A JOINT OPERATING AGENCY P. O. BOX 958 3000 GCO. WASHINCtON WAY RICHL*NO. WASHINCTON 99352 PwOeC (509) 375.5000 h1ay 10, 1979 G02-79-92 Nuclear Regulatory Commission Region V Suite 202, tlalnut Creek Plaza llalnut Creek, California 94596 Attention: R. H. Engelken, Director

Subject:

PIPPSS NUCLEAR PROJECT NO. 2 NRC INSPECTION - FEBRUARY 27-28, hIARCH 1-2, AND htARCH 14-16, 1979 DOCKET NUMBER 50-397

References:

1) Letter, R. H. Engelken to N. 0. Strand, dated April 17, 1979

2) Letter, D. F. Knuth to all AEC Li'censees, dated December 31, 1974, "Criteria for Determining Enforcement Action and Categor-ies of Non-Compliance".

Dear h1r. Engelken:

This is in response to your letter of April 17, 1979, (Reference 1), which documented the results of the NRC inspection conducted on February 27-28, htarch 1-2 and 14-16, 1979 of activities authorized by NRC Construction Permit No. CPPR 93. This letter identified six items of noncompliance wiIich were categorized as infractions and deficiencies in accordance with the pro-visions of (Reference 2) and required that MPPSS provide a response to these items.

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

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

Very truly yours, D, L. RENBERGER Assistant Director Generation and Technology DLR/AMS/ln cc w/att: JG Davis - Office of Inspection 8 Enforcement, llashington, D.C.

>CI Bryant - BPA poi'I g I/~ veas i90c pz'. <

,1 g; APPENDIX A Washington Public Power Supply System P.O. Box 968 Richland, )washington 99352.

Construction Permit No. CPPR-93 Notice of Violation Hased on the results of NRC inspections conducted between February 27 and March 16, 1979, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Facility Li-cense No CPPR-93

~ as indicated below.

A. 10CFR50, Appendix 8, Criterion V, states in part, that "Activities affecting quality...shall be accomplished in accordance with these instructions, procedures or drawings..."

Paragraph D. 2.6 of the HPPSS guality Assurance Program documented in the PSAR states, in part, that "...all project contractors for the nuclear related portions of the plant will be requiredto have a guality Assurance Program...The program shall include the following items as...applicable to the...construction for which the contractor is responsible". Paragraph D.3.$ .5, which follows, states in part, that "Activity affecting quality...shall be accomplished in accordance with...procedures..."

1. Work Procedure SP-2005-H2, Rev. 2, of the Johnson Controls inc.,

a site contractor, states in part, that, "All pipe and tube end-ings will be capped or otherwise closed at the end of each day."

Contrary to the above, on February 27 and Ihrch 1, 1979, the process instrument pipe no. 220-3.0-X-44e, and nine other ports off the reactor vessel nozzle no. N-9Awere found to be open, ex-posing the internals of the reactor vessel.

This is an infraction.

Corrective Action: All ports were taped immediately. Nonconformance Report Number 220-02654 was initiated against nozzle N-9A. The dis-position of the NCR was to clean, inspect and recap. The work was completed and NCR closed.

Action To Prevent Recurrence: Procedure I'Io. gAS-1402-H2 was revised to include daily inspections of such items when placed 'in Johnson Controls (2808-220) custody.

Date of Full Com liance: May 15 1979

Nuclear ulatory Commission Notice o iolation Appendix f, Page Two

2. Exide Company installation instructions for battery racks, entitled "Instructions for Assemblinq Seismic Restraint, Racks for Exide Batteries", requ'ires battery cells to be provided with a snug fit in the racks using plastic spacers in order to meet seismic loading requirements.

Contrary to the above, on February 28, 1979, the plastic spacers installed between cells of batteries Bl-l, B1-2, and B2-1 did not fit sn'ugly between the cells, allowing the cells to move both laterally and vertically, Additionally, no shims were installed between the rack uprights and rails for batteries Bl-l, Bl-2, and B2-1 resulting in about 25 cells of Bl-l and about 10 cells of Bl-2 having 'a gap between cell and rail of about 1/8" to 1/4". These installations were performed and accepted by the Fischbach/Lord Company, a site contractor.

This is an infraction.

Action to Correct Deficienc  : Nonconformance Report Nos. 04285 and 05589 have been written to document the deficiency.

Action To Prevent Recurrence; Fischbach/Lord crafts and inspec-tion personnel will be reinstructed to ensure that installation con-forms not only to applicable drawings and specifications, but also manufacturer's installation instructions referenced in the Installation Procedure Checklist ( IPC).

Date of Full Com liance: June 15, 1979 C. 10CFR50, Appendix B, Criterion X, states in part, that, "A program for inspection of activities affecting quality shall be established and executed...to verify conformance with documented instructions, procedures, and drawings..."

Paragraph D.2.5.10 of the guality Assurance Program, as documented in the PSAR, states in part, that "A program for inspection of activities affect-ing quality shall be established and executed...to verify conformance to documented instructions, procedures, and drawings..."

Contrary to the above, prior to March 1, 1979, the Johnson Controls Inc.,

a site contractor, did not perform inspections of pipe material preheat temperature prior to welding as established by the weld data sheets for work packages of the 220-3-X-44B series.

This is an infraction.

Corrective Action: A Corrective Action Request No. 2 has been issued by Johnson Controls, to document the fact that inspectors were not measuring preheat temperature on the pipe. The pipe in question was stored in the shop and subsequently welded in the shop. The ambient temperature in the shop remains at a constant 70o. The pipe temperature would be greater than the required 60o F, therefore, the welds in question require no additional

action.

Nuclear R ulatory Commission Notice o iolation Appendix Page Three Action To Prevent Recurrence: Contact Pyrometers, traceable to National Standards, were purchased; the inspectors were trained in their usage:.

and the instruments were placed in service.

Date of Full Com liance: Current.

C. 10CER50, Appendix B, Criterion XIV, states in part, that, "Measures shall be established to indicate, by the use of markings such as stamps, tags, labels, routing cards, or other suitable means the status of in-spections...performed upon individual items of the nuclear power plant..."

Paragraph D.2.5.14 of the Quality Assurance Program as documented in the PSAR, states in part that, "Measures shall be established and docu-mented by the contractor to identify inspection. .status.

~ Such measures shall provide means for assuring that required inspections...are performed and that the acceptability of items with regard to inspections...performed is known throughout manufacturing, installation, and operation..."

Contrary to the above, as of February 28, 1979, Johnson Controls, Inc., a site contractor, performed inspections of instrumentation piping welds shown on drawings 220-3.0-X-44Bc, and -44Bf, and -448k without documenting the acceptability of the inspections. In addition, instrumentation piping welds shown on drawings 220.-3.0-X-44Ba, -448b, -44Bd, and -44Be were com-pleted on February 27, 1979, without documenting inspection results until the following day.

This is an infraction.

Corrective Action: The concerned welds were inspected in a timely manner but the documents were not signed off until the next day. The affected documents were reviewed with the inspectors and found to be accurate.

Action To Prevent Recurrence: A training session was held and all Johnson Controls inspectors were instructed to sign off documents immediately upon inspection. Close surveillance of these areas are being conducted by Johnson Controls QA Supervision and Project QA.

Date of Full Com liance: Current D. 10CFR50, Appendix 8, Criterion VIII, states in part, that "Measures shall be established for the identification and control of materials, parts, and components..." and "These identification and control measures shall be designed to prevent the use of incorrect...components".

Paragraph D.2.8.8 of the Quality Assurance Program, as documented in the PSAR, states in part, that "A system of tags and stamps will be employed to provide identification as to the quality status of materials, parts, and components..."

Nuclear ulatory Commission Notice ~iolation Appendix A Page Four Contract specification no. 2808-48 (regarding purchase of 480 volt Class I and Class II switchgear) reouires, in Paragraph 3.4.2, that breakers be positively identified as to guality Class I or Class II.

Contrary to the above, as of )larch 1, 1979, 480 volt breakers installed in guality Class I switchgear (Nos. SL-71, SL-73, SL-81, and SL-83) were not identified as to quality class.

This is a deficiency.

Action to Correct Deficienc  : NCR 48-05586 was written to document this deficiency. The NCR disposition will be for WNP-2 Engineering to issue a PED to Contract 218 (Fischbach/Lord) to identify guality Class I break-ers by appropriate tags.

Action To Prevent Recurrence: All low voltage switchgear breakers have been delivered an installed at WNP-2 and are covered by the NCR No. 48-05586.

Date of Full Com liance: Full compliance will be achieved by June 8, 1979.

E. 10CFR50, Appendix 8, Criterion V, states in part, that, "Activities affect-ing quality...shall be accomplished in accordance with these instructions, procedures or drawings..."

Paragraph D.2.5 of the guality Assurance Program documented in the PSAR states in part, that "...all project contractors for the nuclear related portions of the plant will be required to have a guality Assurance Pro-gram...The program shall include the follow>ing items as...applicable to the...construction for which the contractor is responsible." Paragraph 0.2.5.5, which follows, states in part, that "Activities affecting quality...

shall be accomplished in accordance with...drawings..."

The PSAR, Paragraph 8.8.4,2 states that, "...each cable assigned a segrega-tion code has a colored tag...identifying the segregation code." Fischbach/

Lord Procedure No. gAP 404.1 ( Inspection of Insulated Cable Installation),

specifies that the cable'tag background color be red for division 3 cables and orange for division 2 cables.

Contrary to the above, as of February 27, 1979, the color coded tags for Division 3 cables 3HPCS-0391-C-DIV3, 3HPCS-0091-C-DIV3, 3HPCS-0257-C-DIV3, 3HPCS-0258-C-DIY3, and 3HPCS-0259-C-DIV3 installed by Fischbach/Lord Company, a site contractor, were orange in color.

This is a deficiency.

Action to Correct Oeficienc  : Inspection Report ( IR No. 8244) was written ocumenting t e incorrect color of tags. The tags have been corrected and the IR has been closed.

Nuclear adulatory Commission Not ce o%Fiolation Appendix A Page Five Action to Prevent Recurrence:

1. Fischbach/Lord (F/L) guality Assurance issued a Stop Hork Order No. 16 against continued work. All Class I tags issued to the field were checked to assure compliance to contract specifica-tions. A total of 26 tags found in error were corrected out of 1200 checked. The Stop Work Order was subsequently lifted.

2. F/L Engineering has instituted an additional edit/proofread of all tags issued for installation in accordance with memo FRT 006 F/L Instruction Directive No. 420 is being updated to reflect detailed tag identification requirements,

4. Color charts are now in possession of Construction personnel and are checked by the craftsmen prior to installation. The Termina-tion Group will now be informed directly by the craft of any er-roneous tags prior to installation.

Date of Full Com liance: June 15, 1979 Note: It should be noted that during the course of the surveillance/

inspection and rework to correct this noncompliance, the problem has been found to consist of a color coding problem only. No cases of improperly identified circuits were found.

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