ML19224D520

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Responds to NRC Re Violations Noted in IE Insp Repts 50-460/79-02 & 50-513/79-02.Corrective Actions:Field Change Notice 257-1-79-028 Revised to Reflect Correct Quality Class.Qa Reviewed & Approved
ML19224D520
Person / Time
Site: Washington Public Power Supply System
Issue date: 05/09/1979
From: Renberger D
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To: Spencer G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19224D514 List:
References
GO1-79-297, NUDOCS 7907120456
Download: ML19224D520 (6)


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Washington Public Power Supply Sy~ stem A JOINT OPERATING AGENCY

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fuclear Regulatory Commission N

Region V Suite 202, Walnut Creek Plaza 1990 fl. California Boulevard Walnut Creek, California 94596 Attention: fir. G. S. Spencer, Chief Reactor Construction and Engineering Support Branch

Dear fir. Spencer:

Subject:

WPPSS fluclear Projects flos.1/4 flRC Inspection - W:!P-1/4 Dates of Inspection - February 12-16, 1979 Docket lios. 50-460 and 50-513 Construction Permit flos. CPPR - 134 and 174

Reference:

Letter from G. S. Spencer to II. O. Strand, fiRC Inspection WriP-1 & 4, dated April 3,1979 This is in response to your letter which discussed the results of the February 12-16, 1979 inspection of activities authorized by NRC Corstruction Permi ts !!os. CPPR - 134 and 174.

The reference letter identified certair. activities which were not conducted in full compliance with f!RC requirements, as set forth in the Notice of Violation, enclosed as Appendix A.

These it6ms of noncompliance have been categorized into a level as describod in your corr spondence to all f!RC licensees dated December 31, 1974.

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G. S. Spencer Page 2 The specific f!RC findings, as stated in the reference letter Snd the Supply System responses are provided herewith as Appendix A.

Also included are corrective actions taken to shorten the 10CFR 50.55 (e) process.

Very truly yours, f c2 " h...

- l D. L. Renberger Assistant Director - Technology DLR:TJii:am Attachment cc:

CR Bryant - BPA BD Redd - UE&C, Phil J. Freeman - UESC, Phil k-q, i,

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APPENDIX A Nut' ear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596 Docket Mos. 50-460 and 50-513 Construction Permit Mos. CPPR - 134 and 174 Notice of Violation Based on the results of an NRC inspection conducted during the period of February 12-16, 1979, it appears that certain activities were not conducted in full compliance with NRC requirements as indicated below.

A.

10 CFR 50, Appendix B, Criterion V, as implemented by Section 17.1.5 of the quality assurance program documented in the PSAR and the WPPSS QA Program Manual procedure QAP-2, Paragraph 3.1, states in part that,

" Activities affecting quality... shall be accomplished in accordance with... instructions, procedures, or drawings."

UE&C procedure FGCP-35, " Field Change Notices - Initiation and Processing," in Paragraph 6.0, states that " Quality Assurance will review and approve FCNs that direct field design changes to Quality Class I activities."

Contrary to the above, Field Change Notice 257-1-79-028 issued on January 26, 1979, was not reviewed and approved by Quality Assurance.

This FCN made changes to the diesel generator sole plates which were quality Class I items as defined by Specification 9779-53.

This item is only applicable to UNP-1.

This is an infraction.

Supply System Response Action Taken to Correct the Identified Item V

Field Change Notice 257-1-79-028 was revised on April 26, 1979 to reflect the correct Quality Class.

Quality Assurance reviewed and approved the revised FCN on April 26, 1979 Action Taken to Preclude Recurrence The Field Project Engineering Manager, on May 4,1979, issued a directive to Field Project Engineers and Design Supervisors which requires a verifi-cation as to proper Quality Class of documents prior to issue.

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Appendix A Page ?

Date of Full Compliance Full complian:e achie"ed May 4, 1979.

B.

10CFR 50, Appendix B, Criterion V, as implemented by Section 17.1.5 of the quality assurance program documented in the PSAR and the NPPSS QA Program Manual Procedure QAP-2, Paragraph 3.1, states in part that, " Activities affecting quality... shall be accomplished in accordance with... instructions, procedures, or drawings."

Specification 9779-53, " Diesel Generr. tors," in Paragraph 11.2, states that "All contractor's drawings submitted shall be posted with the WPPSS quality class as designated ir these documents and as called for on the engineer's design drawings." Specification 9779-53 was defined as Quality Class I.

Contrary to the above, on February 14, 1979, ten contractor drawings furnished for installation of the diesel generators at WNP Units 1 and 4 were not posted with the U)PSS quality class designation.

These drawings were located in the UESC drawing control files.

This is a deficiercy.

Supply System Response Action Taken to Correct the Identified Item The contractor has be :n advised that the majority of drawings submitted for the Diesel Generator do not indicate the WPPSS Quality Class as stipulated in Section lA of Specification 9779-53.

The contractor has been requested to resubmit those drawings which do not indicate the UPPSS Quality Class.

The Quality Class for the Diesel Generator is WPPSS Quality Class I.

Action Taken to Preclude Recurrence k

The Field Project Engineering Manager on May 4, 1979 issued a directive to r'ield Project Engineers and Design Supervisors which requires a verific-as to proper Quality Class of documents prior to issue.

The directive als stated the importance of the UPPSS Quality Class to corre-tly note proper identification of equipment with respect tu safety and operation of the Unit.

Da te of Full _Coapliance Full compliance achieved May 4, 1979.

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Appendix A Page 3 C.

10 CFR, Appendix B, Cr terion IV, as implemented by Section 17.1.4 i

of the qua'.ity assurance program documented in the PSAR states that, " Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by the applicant or by its contractors or subcontractors."

Section 17.1.12 of the PSAR states in part, tha t, "WPPSS and UE&C generated procurement documents (shall) be reviewed and approved to verify that requirements have been included which provide for the development and implementation of measures to control measuring and test equipment." Certain requirements for these measures are listed in the PSAR which adoress calibration intervals, required accuracy, intended usage, calibration standards, environment controis, records of calibration history, removal from service, and investigat on of i

previous inspection validity when test equipment is found to be cut of calibration.

Contrary to the above, as of February 14, 1979, the contractor QA requirements delineated in Specifications 9779-211 ar.d 257, WPPSS and UE&C generated and approved procurement documents, did not contain or reference the applicable requirements in the PSAR concerning the measures for controlling measuring and test equipment.

This is a deficiency.

Supply System Response Action Taken to Correct the Identified Item The contractor's procedure for Calibration and Control of Measurement and Test Equipment, P0P-U-704W Rev. 1C, was revised on April 2, 1979 and returned

" Approved as Noted" on April 19, 1979.

Rev. ID to procedure POP-N-704W was resubmitted April 27, 1979, and now addresses applicable requirements contained in the PSAR.

Rev.1D is currently undergoing in-house review.

Action Taken to Preclude Recurrence Quality Assurance personnel have been informed of the necessity to cross reference PSAR and specification requiremerits durinq procedure review cycle.

Procurement documents will be revised to include reference to applicable requirements in the PSAR concerning measures for controlling measuring and test equipment.

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Appendix A Page 4 Date of Full Compliance Contract 211 and 257 procedure P0P-fi-704W has been reviewed by the Project QA organization and complies with PSAR and specification requirements.

The procedure will be returned to the contractor by transmittal and placed in effect by May 21, 1979.

With respect to your concerns regarding reportability of nonconformances pursuant to 10CFR50.55(e), be advised that our procedure has been revised to increase our effectiveness in this area.

QAP-ll Rev 2, dated March 31, 1979 delineates responsibility to the applicable UPPSS Project Engineering and Quality Assurance Managers to determine reportability and process reports under Part 21 and 10CFR50.55(e).

The recen'.e, ort by the Supply System on the Letdown Cooler Supports will increased ef fectivity in this area.

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