ML17277A609
| ML17277A609 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/08/1983 |
| From: | Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8306210120 | |
| Download: ML17277A609 (9) | |
Text
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REGULATORY ORMATION DISTRIBUTION SY 8
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ACCESSION NBRe8306210120 DOC,DATE: 83/06/08 NOTARIZED:
NO DOCKET ¹ FAGIL!50 397 NPPSS Nuclear Projects Unit 2i Nashington Public Powe 05000397 AUTH'AME AUTHOR AFfILIATION BOUCHEY<G.D, l<ashington Public Power Supply System
-REC IP,-NAME RECIPIENT AffILIATION SCHKENCERrA ~
Licensing Branch 2
SUBJECT:
Forwards partial response to TAA830516 audit rept Findings 15 8
16 of independent verification program. Response to Finding 14 forthcoming, DISTRIBUTION CODE:
8001S COPIES RECEIVED:LTR ENCL SIZE;,
TITLE: Licensing Submi ttal:
PSAR/F SAR Amdts 8 Related Corr espondence NOTES:
RECIPIENT ID CODE/NAME NRR/DL/ADL NRR LB2 LA INTERNALS ELD/HDS2 IE/DEPER/EPB 36 IE/DEQA/QAB 21 NRR/DE/CEB 11 NRR/OE/EQB NRR/DE/MEB 18 NRR/DE/SAB 24 NRR/OE/SGEB 30 NRR/DHFS/LQB 32 NRR/DL/SSPB NRR/DSI/ASB NRR/DSI/CSB 09 NRR/DSI/METB 12 NRR D
AB 22 PILE 04 OP%
/MI8 EXTERNALS ACRS 41 DMB/DSS (AMDTS)
LPDR 03 NSIC 05 COPIES LTTR ENCL 0
1 0
1 0
3 3
1 1
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2 2
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RECIPIENT ID CODE/NAME NRR L82 BC AULUCKrR~
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FEMA REP DIV '39 NRC PDR 02 NTIS COPIES LTTR ENCL 1
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Washington Public Power Supply System 3000George Washington Way P.O. Box968 Richland, Washington 99352-0968 (509)372-5000 Director of Nuclear Reactor Regulation Attention:
b1r. A. Schwencer, Chief Licensing Branch No.
2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.
C.
20555
Subject:
INDEPENDENT AUDIT OF WNP-2 PLANT VERIFICATION PROGRAM Enclosed is our response to findings Nos.
15 and 16 of the fRay 16,
- 1983, TAA audit report.
We will provide a response to finding No.
14 at a later date.
If you have questions related to the TAA report or the Supply System response, contact John R.
Honekamp (509) 372-5359.
Very truly yours, Nuclear Safety and Regulatory Programs
Enclosures:
1.
TAA Report 2.
Supply System
Response
cc:
R Auluck NRC RT Dodds NRC JL Crews NRC NS Reynolds D&L A Toth 956B 8306210i20 830608 PDR ADOCK 05000397 PDR
June 8, 1983 PARTIAL RESPONSE TO TAA AUDIT REPORT DATED MAY 16, 1983 TAA Finding 815 The gVP does not inspect certain important construction features sucn as the supporting and securing of power plant components.
This "hole" in gVP's scope should be filled.
Supply System
Response
It is correct that the gYP has not reinspected major mechanical equipment
- supports, however, it is not correct that this fact represents a "hole" in the gVP scope.
The purpose of the gVP is to verify the adequacy of safety-related work completed, inspected and accepted prior to the stop work in July 1980.
Independent of the
()VP, substantial reinspections have been performed as part of the Test and Startup Program and to resolve specific problems identified during and after the Restart Program.
Therefore, the general approach employed by the gVP is to identify the work completed, inspected and accepted prior to the stop work, evaluate any special reinspections performed independent of the gVP, then perform those additional reinspections needed to meet the gYP requirements.
At the time of the TAA audit, this process had not been completed for major mechanical equipment installed by the 215 contractor, hence the general approach was discussed with TAA, but no conclusions were presented relative to the need for reinspection by the
()YP.
This evaluation nas now reached the point where it is clear that all 215 mechanical equipment was transferred to Bechtel prior to the completion of final alignment and document review.
Although installation of some equipment was essentially
- complete, the fact that final alignment and document review were not complete has led the Project to treat all
~IBG equipment installations as incomplete.
Therefore, this element of the 215 Contract work does not fall within the scope of (jVP.
As indicated on pages 7 and 13 of the TAA audit report, this finding was triggered by the fact that shims were observed to be missing from the RHR-B heat exchanger during a Supply System field inspection conducted as part of the Design Reverification Program.
This inspection was conducted on April 27,
- 1983, the day prior to the Finding Review Committee (FRC) meeting attended by TAA during which Potential Finding Reports (PFR)
RHR-24 and 33 relative to this inspecti on were discussed.
The FRC classified these two PFRs as findings and requested a meeting with the Project to determine the status of the installation and the cause of the apparent discrepancies.
Although the Project review is not yet complete, it has been established that final alignment and inspection of the RHR heat exchangers were not completed at the time of the
(2) stop work and that the missing shims were the result of a construction coordination problem that "occurred later when Bechtel assumed responsibility for work that was partially completed by the original 215 contractor.
Since the
()VP addresses work that was completed, inspected and accepted prior to the stop work, this problem which occurred after the stop work is not indicative of a "hole" in the program, therefore, no redirection of the,()VP is required.
This problem will be evaluated and corrected through the ongoing construction and
()A programs.
The construction coordination problem that resulted in the missing shims is characterized by the coincidence of unique installation requirements and the transfer of responsibility for installation work that was partially complete.
As part of our ongoing construction completion program (not gVP),
we intend to increase our confidence that there is not a generic
'roblem with equipment installation resulting from the transfer of responsibility from WBG to Bechtel by reviewing all Contract 215 ()C-I equipment installation packages to assure that vendor equipment installation requirements have been implemented.
Records will be checked to assure that applicable vendor requirements have been incorporated in the installation; assure that closing documentation exists for all equipment installations entered on the MWL; and to assure that open items have been transferred to the TCS.
Where documentation is not adequate to provide objective evidence that these requirements have been met, field verification will be used to assure that they have been implemented regardless of who did the work.
The following sunmary of results from the Project review of the RHR heat exchanger deficiencies provides the basis for our conclusions that the final alignment and inspection was not complete in July 1980 and that the missing shims were the result of a construction coordination problem associ ated with the coincidence of unique installation requirements and the transfer of responsibility for installation work that was partially complete.
1.
The RHR heat exchangers were received in 1975 and installed by WBG in May 1978.
Final alignment and inspection was not complete at the time of the work stoppage in July 1980 as identified in the WBG documentation completion program 'effort (Ref.
WBG BEC-215-82-0363, dated 4/15/82).
The work was sub-se'quently transferred to BPC.
2.
WBG Inspection Report 215-IR-09880, dated 4/5/82, regarding RHR-HX-1A indicated installation documentation is incomplete.
WBG Inspection Report 215-IR-09887, dated 4/19/82, regarding RHR-HX-1B indicated installation documentation is incomplete.
These IRs were closed by WBG with ()C verification of installation and closure to be transferred to Bechtel.
(3) 3.
The GE Specification 22A5233, "Installation Instructions for RHR Heat Exchangers" provided installation instructions for the upper keyway fitup clearances and the lower support clearances between the slotted hole and the bolt.
This instruction allowed either the use of shims or restraining pads for the lower supports.
This specificati on was included in the 215 Contract, Appendix IY.
4.
RFI-PQA-107, dated 1/16/79 identified that foundation detail on BRI Drawing No.S772 does not call for shims or restraining pads for the supports as required by GE Specification 22A5233.
The RFI was dispositioned by agreeing that the changes shall be made to the support bracket per GE instructions and the installation shall be in accordance with procedures and verified by QA/QC.
5.
Letter WNP-2 WBG-215-F-80-1096, dated 4/14/80, transmitted PED 215-CS-2677 which provided direction to install shims on the upper keyway support to reduce the gap (X + Y) on both heat exchangers in compliance with GE Spec.
22A5233.
The PED contained as-built dimensions of the gaps required to be shimmed for both heat exchangers.
6.
GE FDDR KK1-165, dated 3/24/80, was issued to disposition two cases at azimuths 90 and 180 where the as-built "Z" dimensions on the upper keyways exceeded the GE specification.
These cases were dispositioned "use-as-is" based on GE calculations.
7.
A review of WBG heat exchanger work packages found preliminary and incomplete sketches and calculations for restraining pads at the lower support.
Neither the shim installation nor the restraining pads had been completed by the time of the stop work order.
8.
In closing the WBG IRs (item 2) Bechtel addressed the requirements contai ned in GE Specification 22A5233 for torquing the nuts on the anchor bolts, but apparently overlooked the require-ments for shimning the upper and lower supports which are contained in the same document.
TAA Finding No.
16 In view of the gap in the QYP inspection program identified in Finding No. 15, we believe there should be a fresh, systematic appraisal of the QYP scope to determine if there are other significant areas which are'ot covered by it.
Supply System
Response
Our di scussion with TAA representatives on April 29,
- 1983, may have unintentionally left the impression that equipment installations are not being verified.
The Bechtel Reverification Group (BRG)
(4) was performing an evaluation of Project programs which address Contract 215 equipment installation at the time of TAA's visit.
This evaluation will be included in the Contract 215 reverification report.
At our. April 29th meeting, we responded to TAA's questions on the RHR heat exchanger mounting by taking action io investigate whether or noi the missing shims should have been discovered by gYP reinspections.
At the receipt of this audit finding (5/19/83) we were concluding a par of our investigation which has revealed that Contract 215 equipment installations were not completed prior to July 1980, and are therefore outside the scope of gVP (Re:
response to finding llo. 15).
To clear the path for understanding the completeness of ()VP's examination of Contract 215's work scope, not only to determine the total, quantity of nardware to be reinspected but to identify specific items to be selected for reinspection, you may need to be aware that MBG's computer control lists were used as the basis for establi sning the
()YP scope.
These lists provide an identification of work packages for piping, hangers, structural items and equipment; the only substantive categories of work in the contract.
The coverage of gVP reinspections, including Contract 215, is typified in the following lists:
gVP ELEtlEi'ITS Systems Completion Piping and Hangers Structural Steel Equipment Installation Ductwork and Hangers Cable Installation and Terminations Condui.
Support.
IRC Installation Prepurchase 8 Inactive Contracts o
Components and Yalves o
Cable o
Structural Steel o
- Concrete, Resteel and Cadwelds o
Cranes and Hoists o 'iping and Hangers o
mechanical and Electrical Equipment, o
Soil Compacti on o
Instrumentation
(5)
S ecial Tasks o
Design Change Documentation o
Personnel qualifications o
Receiving Inspections o
- Further, many other review, reinspection and evaluation activities serve to compri se the totality of WNP-2 construction verificati on:
"OTHER" VERIFICATION ACTIVITIES o
Secrificial Shield Wall Evaluation and Repair Program o
PWR Review and Repair Program o
WBG Documentation Completion Program o
Restart Program Elements o
Weld Radiograph Review o
Concrete Anchor Evaluation Program o
Backfill Testing Program o
Structural Steel Bolting o
Drywell Steel Inspection o
Special Inspections and Audits by Corporate or Project gA o
Hanger Retrofit Program o
Piping and Hanger As-Built Programs o
TSU's Component Verification Program o
Pre-Service Inspection o
Coating Rework o
Bechtel gA Program Elements We believe the root cause of the RHR heat exchanger support deficiency is a construction coordination problem which occurred during the transfer of responsibility from WBG to Bechtel for completing the installations.
The resulting vulnerability to potential defi-ciencies is limited to Contract
- 215, as no other such transfer of responsibility between contr'actors has taken place.
This issue is being appropriately addressed as described in our response to Finding 15.
In conclusion, the guality Verification Program is soundly based on our comprehensive assessment of the construction work in place prior to the stop work, and our careful consideration of that work for possible reinspecti on.
No further apprai sal of the gVP scope is necessary.