ML17272A500
| ML17272A500 | |
| 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) |
| Shared Package | |
| ML17272A495 | List: |
| References | |
| GO2-79-92, NUDOCS 7907030088 | |
| Download: ML17272A500 (12) | |
Text
Washington Public Power Supply System JOINT OPERATING AGENCY P. O. Oox 900 3000 Gxo. WASloNGTON WAY AICHLAHD WASHINGTON 99352 Pscosc (SO9) $75 5000 Nuclear Regulatory Commission Region V
Suite 202, 'lialnut Creek Plaza llalnut Creek, California 94596 Hay 10, 1979 G02-79-92 Attention:
Subject:
R.
H.
- Engelken, Director MPPSS NUCLEAR PROJECT t'l0.
2 NRC INSPECTION -
FEBRUARY 27-28, MARCH 1-2, AND t~ARCH 14-16, 1979 DOCKET NUMBER 50-397
References:
1)
- Letter, R.
HE 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 Categor-ies of Non-Compliance".
Dear Hr. 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, t1arch 1-2 and 14-16, 1979 of activities authorized by NRC Construction Permit No.
CPPR 93.
This letter identified six items of noncompliance which were categorized as infractions and deficiencies in accordance with the pro-visions of (Reference
- 2) and required that HPPSS 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.
Ver+.truly yours, w~pP~
D. L.
RENBERGER Assistant Director Generation and Technology DLR/At1S/ln cc w/att:
JG Davis - Office of Inspection 8 Enforcement, tlashington, D.C.
'C< Bryant -
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APPENDIX A j
Washington Public Power Supply System P.O.
Box 968 Richland, llashington 99352 Construction Permit No.
CPPR-93 Notice of Violation Based on the results of NRC inspections conducted between February 27 and t1arch 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 B, 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 MPPSS 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 Program...The program shall include the following items as...applicable to the...construction for which the contractor is responsible".
Paraoraph D.3.5:.5, which follows, states in part, that "Activityaffecting quality...shall be accomplished in accordance with...procedures..."
1.
i(or k 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 March 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'mmediately.
Nonconformance Peport 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 No. 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:
Hay 15; 1979
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Notice of Violation Appendix P
Page Two 2.
Exide Company installation instructions for battery racks, entitled "Instructions for Assemblinq Seismic Restraint Racks for Exide Batteries", requires battery ce'l'ls 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, Bl-2, and B2-1 did not fit snugly 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, 81-2, and B2-1 resulting in about 25 cells of Bl-1 and about 10 cells of B1-2 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
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 equality 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.
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Appendix A
Page Three 0 ld 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.
- 10CFR50, Appendix B, Criterion XIV, states in part, that, "f'Ieasures 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'he PSAR, states in part that, "Yieasures shall be established and docu-mented by the contractor to identify inspection...status.'uch measures shall provide means for assuring that reouired 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 -44Bk without documenting the ac'ceptability of the inspections.
In addition, instrumentation piping welds shown on drawings 220.-3.0-X-44Ba,
-44Bb, -44Bd, and -44Be were com-pleted on February 27, 1979, without documentinq 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 Contro s 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
- 10CFR50, Appendix B, Criterion VIII, s.ates.
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'SAR, 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..."
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Notice of Violation 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 equality Class I or Class II.
Contrary to the above, as of tlarch 1, 1979, 480 volt breakers installed in equality Class I switchgear (Nos.
SL-.71, SL-73, SL-Gl, 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 MNP-2 Enqineering to issue a
PED to Contract 218 (Fischbach/Lord) to identify equality Class I break-ers by appropriate tags.
Action To Prevent Recurrence:
All low voltage switchgear breakers have been delivere an installed at lJNP-2 and are covered by the NCR No. 48-05586.
Date of Full Com liance:
Full compliance will be achieved by June 8, 1979.
- 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 equality 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 equality Assurance Pro-gram...The program shall include the following items as...applicable to the...construction for which the contractor is responsible."
Paragraph D.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 seqrega-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-DIV3, and 3HPCS-0259-C-DIV3 installed by Fischbach/Lord
- Company, a site contractor, were orange in color.
This is a deficiency.
Action to Correct Deficienc 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.
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Notice of Violation Appendix A
Page Five Action to Prevent Recurrence:,
2.
Fischbach/Lord (F/L) equality Assurance issued a Stop t!ork Order No.
16 against continued work.
All Class I taas 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 Hork Order was subsequently lifted.
F/L Engineering has instituted an additional edit/proofread of all tags issued for installation in accordance with memo FRT 006.
3.
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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