ML17272A496

Responds to NRC 790417 Ltr Re Violations Noted in IE Insp Rept 50-397/79-04.Corrective Actions for QA Program: Initiation of Periodic Reindoctrination Programs for Managers & Audit of Contractor QA Records

ML17272A496
Person / Time
Site:	Columbia
Issue date:	05/18/1979
From:	Strand N WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17272A495	List: ML17272A496 ML17272A500
References
GO2-79-100, NUDOCS 7907030084
Download: ML17272A496 (10)

Text

Washington Public Power Supply System A 3OINT OPERATING AGENCY P. O. BOX 958 3000 GCO. WASHINC'ION WAY RICHLAND, WASHINOfON 99352 PHON C (509) 3'75 5000 Hay 18, 1979 G02-79-100 Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza Walnut Creek, California 94596 Attention: R. H. Engelken, Director

Subject:

WPPSS NUCLEAR PROJECT NO. 2 NRC INSPECTION - FEBRUARY 27-28, MARCH 1-2, AND MARCH 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 Licensees, dated December 31, 1974, "Criteria for Determining Enforcement Action and Categories of Non-Compliance".

Dear Hr. Engelken:

C As requested in reference letter, we are implementing additional and immediate actions required to assure that ongoing construction activities are accomplished according to qual i ty requi rements.

Since our Hay 1978 conference, we have initiated actions to strengthen the WPPSS and the contractors gA Proqrams. However, we still have a need for continuing and increased attention in the following areas:

'1. Responsibility of Project Managers, Construction Managers and Supervisors for enforcement of job quality requirements.

2. Improve contractor training and the problem feedback'loop to firstline personnel .

3. Improve preplanning to prepare contractors before commencement of guality Class I work.

4. Streamline contractor procedures to eliminate overly complex and unnecessary requirements.

VQOVO39g72P

Nuclear Regulatory Commission c, pi Page 2 Some of our major actions, planned or underway, to address these specific areas and our overall gA Program are listed below:

We have initiated a detailed assessment and evaluation of our "guality Assurance Proqram Corrective I'1easures," submitted to you by letter of September 1, 1978, in response to our Hay-June 1978 enforcement conferences.

Target for completion of the evaluation and followup plan of action is

~37 31. 1979.

2. The Assistant Director-Projects has initiated a program of periodic reindoctrination of Project Hanagers and their Construction t1anagers and Supervisors for enforcement of job quality requirements.

3. WPPSS will instigate the training of craft supervisors and management:

of'elected major WNP-2 contractors. The training module for craft supervision is one specially prepared by our architect-engineer for foreman level. Target date for completion of this module is August 1979.

4, We are now reviewing with WNP-2 contractors their system for problems feedback to crafts and firstline inspectors. We will improve the system where necessary. Expected completion date is June 1979.

Before any new guality Class I work coranences, WNP-2 Construction ttanagement will ask for a gA audit to generally review the readiness. Work will not be allowed to except in contractors'verall proceed areas not affected by the review and audit findings. 'hose

6. Because we have been concerned about the adequacy of our for controlling their gA records, we have just audited their contractors'rogram programs and will improve them where necessary. We have personnel assigned tor ongoing review of records. To gain the necessary assurances, we, have assigned and located document review personnel at three of the critical contractors'ocument control areas. On Contract 215, our Construction management has been directing an effort to transfer documents from the field to the records vault.

7. In support of our Construction Management-Systems Completion Group, we have established a guality Completion Grqup with Project gA. The latter group will support Systems Completion and Startup by timely identification and resolution of inspection backlogs and quality-related deficiencies.

8. On Contract 216, Waldinger has replaced its Project Manager and gA )1anager and we are demanding their highest corporate attention to solve the gA problems. We are having weekly Project t1anagement meetings with them on gA problems. A joint Project-Contractor Task Force of Engineering/

Construction/gA-gC personnel has been started to speed up inspection backlogs. By June 1979, we plan to review and streamline Contract 216 procedures to delete overly complex and unnecessary requirements.

Nuclear Regulatory Commission

( c~ Page 3 He are also having weekly Project f1anagement meetings with Contract 220 (Johnson Controls) on quality problems and are .expediting their program impl'ementation. We took stop work actions in April in two areas where existing procedures were inadequate. By June 1979, we plan to review and streamline contractor procedures to delete overly complex and unnecessary requirements.

10. You are aware that our efforts significantly improved the Contractor's

'A Program over the last one-year period. Because of the 215 size, importance and past history of the 215 Contract, we will continue to give this contract our close attention including improvement of hanger inspection backlogs.

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

V ery truly yours,

l. 0. Strand Managing Director vh cc: JG Davis - Office of Inspection 5 Enforcement, Washington, D.C.

CR Bryant - BPA

V W. >u-sv/

&ITe lF 8/DAD R'e'u'oe EELY 047K ~RQQCl. MYOID A~TOS Statu.

7. Clsd 79-06/Var. N.A. (TMr P MRS) - Not Applicable- Clsd 79- pen 79-08/4149 N.A.

~617 ~IQMKIMP~tures)~mpone~ot-used 4-WNP 2 79-10/5119 N.A. MRQllQ 79-11/5229 7229 8069 ~sedQHN~~sc 79-12/5319 N.A. BW 79-13/6259 N.A.

79-14/7029 N029 9 7 + 911 79-15/7119 9119 9189 De DF 79-16/7269 9219 9059 ls 79-17/7269 N.A. PW 79-18/8079 N.A. A di 79-19/8109 N.A. Pk Low v W 79-20/8109 N.A. Pk ow 79-21/8139 NBA.

Cp'- I N.A.

79-23/9129 0279 N029 79-24/9279 N.A.

79-25/N029 79-26/N209 79-27/N309 79-28/D079 79-01B/1140 1020 N.A.

N.A.

2070 N.A.

1280 a~

~ ~i (Emir QaalMqaig=Wnrking-edNod pen pen 79-17 0299 N.A. aa 79-142L9079 N.A. Qzuidance~&miltMe~n~naly~)~Info for.. 7EL14 }~lsd 79-03A/4040 8040 LOOen) Q o.ng~Wj.~ejeMa) U pan 79-01B/2290 N,A. (Environ ..Qual. Equip) = Moxking- Open 80-01/1110 N.A. EAds ~L~~O wzabili ty3 Open 80-02/1210 5210 (ape~a Lt. s a* Ml Open 80-03/2060 3180 Working Oper 3210 (Loss oC CharcoaU 80-04/2080 N.A. (PWKglain Lina&k),.=Eat Applicable= Clsd 80-05/3100 (80-06/3130 N.A. (GgCCS XK Daraage). ~= Horking Open N.A. (jHF.preset Contr) ~ . Marking Open 80-07/4040 N.A. {W~mp Failure) - Morkin 80-08 4070 7070 caen) ( incr .Re~e1ds.).~fazking-80-09/4170 6170 ~pen (Hydromotor Actuatorsg Working Bpep 1Extension Req ested/Gran ed ATTACHMENT 4

Ps gs VV '9 I i >-el ov

'ITE WNP-2 IEW))7c()(.~s EC /Dim CoQRGc7l ve 4c~og /sag STATUS Not A licable

~79-07 5029'9-08 (RRC WG Set~g eed Increase Com onent not used WWP-2 5189 79-09 6229 (SCBA Problem Workin 79-10/6269 (Unaccep, PigeeFt ss) Wor 79-11/6279 (Desig~n Const. Interface Prob Wo ki 79-12/6289 D.G. Turboche Prob Wo kin 79-13/7139 ~Fire Pum Contactor Prob Defective r s e 79-14/7139 QUnauthor. Procur. Xenon-133 Not a lies le 79-15/8089 SCBA Prob Workin 79-16/8169 Over Ex . Radio ra her Public Not A 79-17/8149 G.E. Ckt. BRR Prob Workin 79-18/9109 Im ro er Install of SRV - Workin 79-19/9139 . Loose Lockin Devices Pum s Not a e w 79-20/9249 Rela Failure Worki 79-21/0199 Un lanned release Worki 79-22/N169 POV Stroke Times Worki "79-23/N269 ~Starter Contactor Failures Com ongDI~~

79-24/N269 /Install Calib CS Pi e BRK Detect . g(~~

79-25/D209 /Shock Arrestor Strut Ass C 79-25A/1310 ~Shock Arrestor Strut Ass 80-01/1170 (GE Service Advice 80-02/2010 (Staff Wk Hrs 80-03/3060 Wo+~

80-04 /3140 (Securing Thrd Lockin~D~e ines)- Wogking-80-05/4010 (D.G. Lub Oil Addition Onsite SuRPJE) ~Wking-80-06/4140 (Contr~ol Account. Therap~ Source~s Uq~ppjig lsd 80-07/4030 (HPCI Turbine Probs -Wo k+'-

80-08/4180 (BWR Tech~S ec Inconsistg Working-80-09/4280 (Commun.,kg~st.~Probe Working 80-10/4290 (Fail. to Maint. Envir~ualif}- Work~

ATTACHMENT 5 gs

lJQI fTEiiJ AT'J F. g5528'cT c,otzuecrÃe Mpio7J 4/27/79 4/30/79 BIF valve a~stator m~avibr. off shaft Satisfactor 4/27/79 5/31/79 Whi restraint'teel defects P bus Steel Satisfactor 5/04/79 5/31/79 Poor solderin W enetration Satisfactor 6/21/79 7/16/79 Ess ~ fan su lied from noness. source Satisfactor 6/21/79 7/20/79 Satisfactor 6/21/79 8/02/79 G.M. Diesel en ine problem Satisfactor 6/28/79 8/07/79 ~im ro erl installed anchor bolts Satisfactor 9/21/79 10/18/79 ECC um room flood from fuel ool condensat Satisfactor workin 10/04/79 10/31/79 Incorrect lu weldin between SSW rin s 3 4 workin 11/21/79 12/10/79 Irre ularities in i e whi restraint record workin 2/19/80 3/19/80 Possible water hammer in RCIC i ing Satisfactor workin 2/19/80 3/21/80 oten'tial missiles ad'acent to RPS MG sets workin 3/19/80 4/21/80 Poor control of small i in desi n chan es Satisfactor workin 3/19/80 4/21/80 Im ro er weld re of small bore i in workin ATTACHMENT 6

JUSTIFICATION FOR INCREASED INSPECTION FREQUENCY CONCERN EXAMPLES guestions exist in the The sacrificial shield wall, completed in June, acceptability of completed 1978 has been found to,be seriously deficient, safety related work. indicating quality controls during the period of fabrication and erection were not as effective as required. (IE Inspection Reports 50-397/79-12, 13, 16, 80-04)

The pipe whip restraints, completed in February, 1977 have been found to be seriously deficient, indicating quality controls during this period were not as effective as required. (IE Inspection Reports 50-397/80-04)

The postweld heat treatment of pipe welds conducted during the period of February, 1977 to 1979 was found to be seriously deficient, indicating quality controls during this period were not as effective as required.

(IE Inspection Report 50-397/79-10)

The pipe support installation/inspection program up to May, 1978 was found to be seriously deficient and was the subject of 9 items of noncompliance during Dec.

1977-May 1978, indicating prior quality controls were not effective. (IE Inspection Reports 50-397/77-07, 78-03, 80-06).

HVAC installation (including safety related portions) up through 1978 was found by the licensee to be sufficiently deficient to require a 100/ reinspection.

(IE Inspection Report 50-397/79-04)

In 1978, the licensee found piping contractor welding procedures to have nontraceable test results and other problems requiring "re-qualification" of all procedures.

(IE Inspection Reports 50-397/79-14, 79-16)

Licensee control of current Pipe support installation, the subject of 5 items of noncompliance in 1977, 4 items of noncompliance in 1978, work activities. (This concern is further defined item of noncompliance in 1979, is again the subject of in items 3, 4, and 5 below). an item of noncompliance in 1980. (IE Inspection Reports 50-397/77-07, 78-03, 79-03, 80-04).

,Ability to maintain component and equipment cleanliness continues to be a problem site management has not been effective in resolving. Cleanliness was the subject of 4 items of noncompliance in 1979 and one in 1980. (IE Inspection Reports 50-397/79-01, 79-04, 79-16, 80-04)

(For additional examples refer to items 3 and 4 below) .

JUSTIFICATION FOR INCREASED INSPECTION FRE UENCY (cont.)

CONCERN EXAMPLES Timeliness of identification NRC identified a concern on the seismic qualification of of .problems to site and electrical conduit clamping devices in October 1978. As licensee headquarters of April 1980, the licensee has still not determined which management, and timeliness clamping devices will perform to seismic requirements.

of response to problems. Some steps were taken in January 1980 and April 1980 to restrict the type of clamping device to those which show the most promise in meeting seismic testing requirements; however, many devices installed between 10/78 and 1/80 may require reinspection/replacement. (IE Inspection Reports 50-397/78.-10) 78-11, 79-04, 79-09, 80-06)

Electrical separation requirements has been an NRC concern since October 1978. The licensee's requirements in this area have been changed by the licensee but were not formally submitted to NRR as of April 18, 1980. The latest set of requirements do not appear to comply with current industry standards and have the potential for resulting in significant rework if disapproved by NRR.

NRC: RV concerns with the new cr iter ia have been for-warded to IE:Hg for submittal to NRR.

Environmental qualification of electrical components has been an NRC concern since March 1979. While the licensee has been active in this area the actions have not been completed. (IE Inspection Report 50-397/

79-04).

In August 1979, the NRC pointed out an inconsistency between the PSAR and the 215 contractor's inspector qualification procedure. As of February 1980, no effective action had been taken. (IE Inspection Reports 50-397/79-14, 80-04).

JUSTIFICATION FOR INCREASED INSPECTION FRE UENCY (cont.)

CONCERN EXAMPLES Thoroughness in performing Licensee management was advised by their contractor evaluations of problems. of problems with the sacrificial shield wall in November, 1978. A corrective action plan was developed and implemented in March, 1979. In June, 1979, the NRC received allegations concerning the wall. Investigation at that time established that validity of Leckenby sacrificial shield wall records was in question (a thorough licensee evaluation during November, 1978 to March, 1979 should have identified this concern). In July, 1979, the licensee's corrective action program was expanded to include a quality review of the Leckenby program.

This review was effectively completed by November 30, 1979 without identifying significant problems in Leckenby gA program, which were identified by the NRC investigation of 11/27/79 to 2/28/80. In addition, in October, 1979, the NRC identified that licensee's engineering review for structural acceptability of the wall (which started in March, 1979) was being performed on an incomplete data base (engineers were plotting/extrapolating typical wall defects in lieu of all actual known defects).

(IE Inspection Reports 50-397/79-12, 79-13, 79-16, 80-04)

Licensee reported major defects in Leckenby electro-slag welds for certain pipe whip restraint brackets in a 50.55(e) item in March, 1979. Of the 45 brack-ets fabricated 20 had to be completely rebuilt, 14 were repaired, and 11 were found acceptable. The licensee's evaluation of the problem failed to address other electroslag welding done by the same contractor for WNP-2 (i.e., the sacrificial shield wall and pipe whip restraints) which turned out to have significant welding deficiencies as well as major quality problems. A thorough evaluation should have surfaced many of the Leckenby problems later identified by the NRC. (IE Inspection Reports 50-397/79-06, 79-12, 79-13, 79-16, 80-04).

Although the licensee has Refer to item 2 above for examples.

made significant improvements in training with their g-Tips program, further improvement is warranted in the licensee's program for personnel training and problem feedback in view of the repetitive nature of several items of noncompliance during the past year.

V