ML19339C785
| ML19339C785 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 08/13/1980 |
| From: | Ferguson R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19339C782 | List: |
| References | |
| G1-80-225, GO1-80-225, NUDOCS 8011190455 | |
| Download: ML19339C785 (8) | |
Text
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'g-pk Washington Public Power Supply System N
A JOINT OPERAIING AGENCY 5
August 13, 1980 G01-80-225 Nuclear Regulatory Commission Region V O
Suite 202, Walnut Creek Plaza 1990 North California Boulevard i
s Walnut Creek, California 94596 b.
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y Attention:
Mr. R. H. Engelken, Director Gentlemen:
Subject:
WPPSS NUCLEAR PROJECTS NOS.1 AND 4 NRC INSPECTION - WNP-1/4 DATES OF INSPECTION - APRIL 29 - MAY 2,1980 DOCKET NOS. 50-460 AND 50-513 CONSTRUCTION PERMIT NOS. CPPR-134 AND -174
Reference:
Letter from R. H. Engelken to N. O. Strand, NRC Inspection at WNP-1/4 Site, dated July 11, 1980.
The reference letter provided the results of the April 29 - May 2,1980 inspection of activities authorized by NRC Construction Permits Nos.
CPPR-134 and -174.
Further, the reference correspondence identified that certain activities were not conducted in full compliance with requirements, as indicated in the Notice of Violation enclosed as Appendix A.
These items of noncompliance have been categorized into a level as described in your correspondence to all NRC licensees dated December 31, 1974.
In addition, in Appendix B you expressed concern about ineffective corrective actions.
This letter is transmitted in response to the reference correspondence.
The specific NRC Violation / Finding, as identified, and the Supply System response is provided herewith as Appendix A and B, rescectively.
Should you have any questions concerning this response, we will be glad to discuss them with you.
,Very truly yours, t
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R. L. Ferguson,i Managing' Director vh Enclosures (2) cc: JR Lewis - BPA CR Bryant - BPA V Mani - VE&C, Phil.
GS Spencer - Chief Reactor Construction and Engineering Support Branch 8011190 g
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APPENDIX A Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard 4
Walnut Creek, California 94596 Docket Nos. 50-460 and 50-513 Construction Permit Nos. CPPR-134 and -174 l
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Based on the results of an NRC inspection conducted during the period of April 29 - May 2,1980, it appears that certain of your 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, 1
states in part that, " Activities affecting quality... shall be accomplished in accordance with... instructions, procedures, or drawings."
The hanger inspection checklist of the J. A. Jones Construction Company, the site contractor responsible for installation and inspection of hangers for safety related piping, requires verifi-catibn that U-bolt connections are tight. Additionally, J. A. Jones Instruction No. JAJ-WI-010.1, Revision 1A, paragraph 8.7 states ihat "Af ter completion of hanger installation, including the Jocumentation required on Hanger Installation Sketch, the hanger will be tagged with an orange adhesive tag, to prevent any further work without notifying Project Engineering and QA.
If additional work is approved, documentation for the work must be provided by J. A. Jones Engineering."
Contrary to the above, on May 1,1980 at Unit.1, pipe hangers Nos. DHR-15-SG-19 and DHR-15-SG-20 supporting safety related piping had loose U-bolt connections. This nonconforming condition wa not identified and the hanger inspection checklists documented that ~ these U-bolt connections had been inspecteo and found acceptable. Orange adhesive tags were applied to the hangers and.
.no documentation demonstrated that additional work on the hanget s subsequent to the inspection and tagging had been approved.
This is an infraction.
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s Appendix A Page 2 SUPPLY SYSTEf1 RESP 0fSE Corrective Action Taken and Results Achieved The U-bolt connections on the affected pipe supports were inspected and found acceptable by the contractor's QV on January 11, 1980.
Subsequent construction activities necessitated the removal of the U-bolt connection to adjust the related piping assembly. The contractor's personnel failed to follow their procedures which require documenting construction activities which modify a previously acceptable installation.
Surveillance Report #848 on Contract #257 documented a check of five (5) pipe supports which had been preliminarily accepted by JA Jones QV. Three (3) of the five (5) had loose or missing U-bolts. JA Jones was notified by CilR of this condition. CllCR's were generated to correct the conditions (1-Cf1CR-257-938, 939 and 940). The Engineer dispositioned the CflCR's " rework" to retighten or install bolts and generate supplemental documentation for the rework. The reinspection of the CflCR's will document the acceptability of the rework.
Corrective Action Taken to Preclude Recurrence The contractor.will place additional emphasis on this activity by conducting training sessions to reiterate the requirements for performance of additional work on hangers and the issuance of proper documentation for activities which have received preliminary acceptance and now require subsequent supolemental inspection to verify the additional work performed.
It should be noted that preliminary acceptance does not relieve the inspector of assuring that the support meets all_ of the installation / inspection criteria at the time of final acceptance.
Paragraph 4.5.5 of JA Jones Ifistruction ITI-005, Rev. 2A; " Inspection Instructions for Hangers, Supports and Restraints" states:
"4.5.5 When all inspections have been performed and all documentation is complete and accurate, the Quality Verifica ; ion Inspector shall sign and date for "QV Acceptance".
4.5.5.1 The inspector shall then place an orange " Preliminary Acceptance" tag on the support indicating that the support is acceptable on that date.
4.5.5.2 Fi n:.1 inspection of the support will be performed prior to system test. Preliminary acceptance does not relieve the inspector of assuring that the support meets all the installation / inspection criteria at the time of that acceptance."
Project Quality Assurance will increase surveillance of this activity to identify any trends.or similar conditions.
Further action such as Corrective Action Requests and/or work stoppage will be taken as necessary.
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' Appendix A Page 3 Date of Full Compliance The rework and subsequent reinspection of the U-bolt connections will be delayed until resolution of the existing labor dispute.
10 CFR 50, Appendix B, Criterion Xill as implemented by Sectico 17.1.13 of the quality assurance program documented in the PSAR and the WPPSS QA Program Manual Procedure QAP-16, Paragraph 4.1, states in part that
" Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment... to prevent damage or deterioration".
Paragraph 6.1.2 of procedure P0P-N-405W of the J. A. Jones Construction Company, a site contractor responsible for construction activities involving safety related piping and components, states that for piping and components, " Protective covering, end caps and other protective services will be utilized and maintained." Further, paragraph 6.3 of J. A. Jones procedure JAJ-Wl-005, Revision 2E, states that, " Space heaters for equipment set in place shall be energized within two (2) days after equipment is installed."
Contrary to the above, on April 29, 1980:
1.
At the J. A. Jones laydown yard for Unit 1 piping, s)fety related stainless steel pipe spool No. DHR-415-040-55 had one erd uncapped and contained a quantity of water, and safety related stainless steel pipe spool No. BRS-C106-84-51 had both ends uncapped.
2.
The b6wl of Unit I reactor coolant pump No. Pl A2, a safety related component, was uncovered and the bowl contained debris including food, newspaper and paper products.
3.
At the 455' elevation of the Unit 1 General Services Building, several uncovered safety related stainless steel pipe spools and valves for Unit I were temporarily stored without protective caps installed and were covered with dirt from concreting work.
4.
At the 399' elevation of the Unit 4 General Services Building, space heaters were not energized in the safety related electric motors of three make-up system pump units, two containment spray pump units and two decay heat removal pump units.
5.
The flanges of Unit 4 make-up system pump MUS-PMP-1A, a safety related component, were open and no protective covering or protective caps were installed.
This is an infraction.
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Appendix A Page 4 SUPPLY SYSTEM RESPONSE Corrective Action Taken and Results Achieved Item 1: Surveillance report 818 (Contract 257), dated 5/5/80, to JA Jones identified the fact that pipe caps were missing. JA Jones responded to the report stating that the condition would be corrected by 5/8/80.
Reinspection by the QAE on 5/14/80 indicated that the condition had been corrected and the storage conditions were acceptable.
Item 2: Surveillance report 252 (Contract 211) dated 5/5/80, checked all four (4) reactor coolant pump bowls for cleanliness and preservation a ttribu tes. Conditions at that time were acceptable for all four (4) pumps indicating that tha conditions identified by the Inspector had been corrected. A follow-up surveillance'vas performed on 5/30/80 (report 272) and was also satisfactory.
Item 3: Surveillance repoi t 852 (Contract 257) was generated on 5/27/80. All pipe checked was properly capped.
Pump bases on elevations 395', 399',
421' and 455' were free of any debris.
Conditions observed were acceptable.
Item 4: 1-NCR-257-03 was generated on 5/1/30 as a result of this condition.
The disposition on 5/7/80 required J. A. Jones to inspect the pump motors following energization of space heaters and megger test the motors.
Results are to be forwarded to Owner's PM Coordinator. The disposition action and closure is pending return of craf t personnel. The space heaters have been energized and "hard-wired" to the equipment.
Item 5: Surveillance report 19 (Unit 4, Contract 257) was generated on 5/1/80.
One hundred percent (100%) of the Contract 257 equipment in the Unit 4 GSB was surveilled. Deficiencies in the areas of c!eanliness and protective covering were noted. JA Jones was notified by CNR of the conditions cod responded that corrective action would be completed by 5/12/80. A reinspection of the conditions on 6/19/80 showed the work to be complete and conditions acceptable. The CNR was closed.
Corrective Action Takea to Preclude Recurrence l
Actions to preclude recurrence of problems of this nature are outlined in our response to item C of Appendix B of this report.
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s APPENDIX B fluclear Regulatory Conmission Region 'I Suite
.,,2, Walnut Creek Plaza 1990 ti. California Boulevard Walnut Creek, California 94596 Cocket flos. 50-460 and 50-513 Construction Permit Nos. CFPR-134 and -174 i
FINDIf1GS REGARDING INEFFECTIVI CORRECTIVE R TIONS The results of an NRC inspection conducte.1 during the period April 29 - May 2, 1980 included findings wherefrom it appears that certain of your corrective actions taken on identified quality problems were ineffective and failed to 1
meet your ccmraitments to the NRC as indicated below:
A.
In February 1979, the NRC inspector identified that your diesel-generator contractor failed to fulfill a specification require-ment to designate the quality class on equipment drawings.
In your response of May 9,1979, to this office, you indicated that the quality class designation assures proper identification of equipment and actions had been taken to correct the omission.
During our review of this matter in June 1979 (reference:
IE Inspection Report No. 50-460/79-09) we brought to your attention that the omission had not been corrected. As of April 29, 1980 this problem remained uncorrected although your diesel-generator contractor submitted several equipment drawings to your after May 4, i
1979 without the quality designation and these drawings were then issued by WPPSS.
l, SUPPLY SYSTEM RESPONSE The effectiveness of corrective actions relative to the resolution of Quality Class designation on equipment drawings is recognized, however, mitigating circumstances are extended for your evaluation. Our initial resonse of May 9, 1979 indicated that actions had been taken to correct the omission. A letter was sent to the diesel-generator contractor and instructions issued to Project Engineers and Design Supervisors to check the quality class designation on all documents prior to issue. Your Inspection Report Nos. 50-460/79-08 and 50-513/79-07 confirmed that we had in fact completed the actions indicated in our response.
On several occasions, vendor surveillance representatives from both United Er/;meers and Constructors and the Supply System have verbally requested during their visits to the manufacturer's facility that the resubmittal of drawings be accomplished in an expeditious menner. A series of escalated actions culminatino in withholding payment were necessary to close out this item.
l At the time of the initial inspection, fabrication of the diesel generators was complete and installation work was in progress, we believe this impacted j
the contractor's sense of urgency.
Inmedietely after your April 29, 1980 inspection, all drawings were resubmitted denoting the proper WPPSS quality class designation. Your inspection of July 15-18, 1980 verified and closed this item.
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< A1pendix B Page 2 Findings Regardinq Ineffective Corrective _ Actions B.
In February 1979, the NRC inspector identified that your procurement documents to a contractor did not include or reference those measures delineated in the PSAR which you connitted to use for controlling measuring and test equioment.
In your response of May 9,1979, to this office, you stated that the contractor procurement documents would be revised. During our review of this matter in June 1979 (reference:
IE Inspection Report No. 50-460/79-07), we brought to 3
your attention that the procurement documents had not yet bt i t
revised. As of April 29, 1980, these documents still had not been revised. Your representatives then stated that revisions may not be necessa ry. However, we understand that a change in your commitment has not yet been authorized nor has a change been submitted to this office for review.
SUPPLY SYSTEM RESPONSE i
We acknowledge that our performance in resolving this finding has not been totally satisfactory. We have completed our review of the PSAR requirements, procurement documents, regulatory requirements and ANSI Standards and concluded that the procurement document should be revised to include or reference thost.
measures delineated in the PSAR. We anticipate that the procurement document will be revised and issued to the contractor by September 15, 1980.
It should be noted that the inspection item 50-460/79-07/01 identified a condition where inadequate procedures for control of the calibration of measuring and test equipment was not in accordance with PSAR requirements in this area.
It is further noted that your inspection report No. 50-460/80-06 and 50-513/80-06 verified that revision 3 of P'0P-N-704W and revision 1 of ITI-013 included r
specification and PSAR requirements in this area.
In addition, your report indicated that the control and calibration of selected calibration equipment and environmental control was found to be satisfactory. This item is closed.
Findings Regarding Ineffective Corrective Actions C.
For the past nine months various cleanliness end preservation problems with safety related equipment at th' site have been noted by NRC inspectors (reference:
IE Ins' action Reports. 50-460/79-10,
-11,-12.-14 and 80-03).
Such problems were similarly identified 1
and documented in numerous surveillance reports by your site QA/QC inspe'ction staf f.
Despite identification of these continuing problems, the actions taken to correct their cause and preclude recurrence have 4
been ineffective as demonstrated by our findings during our recent site inspection. Their findings included five instances where the cleanliness and preservation of safety related components were compro-l mised by the inactions of your site piping installation contractor.
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.Appencix B Page 3 SUPPLY SYSTEM RESPONSE Actions to control the cleanliness and preservition of safety related components have escalated since the identification of this item. The contractor was informed that the Supply System considered housekeeping a serious problem.
The contractor created a single point of contact to resolve unsatisfactory conditions in a timely manner. A single point of contact for each area of the project has also been established within the construction management organization to assure adequate response to identified deficiencies. Addi-tionally, Project Quality Assurance has initiated a program of systematic i
surveillance of installed safety related components on a weekly basis to ensure that housekeeping and equipment preservation measures are being implemented.
Essentially, this program consists of identifying the component installed by elevation, building, ce zone and verifying that the component is being properly mainta ined. Deficiencies related to general housekeestag/ cleanliness are reported directly to Construction Management or preventative maintenance personnel for a
corrective action.
Repetitive conditions are identified to the contractor through corrective action requests and other escalated enforcement actions, as applicable.
We wish to reiterate that with the area manager concept, and single point of contact, as well as direct control of preventive maintenance by the Preventive Maintenance Coordinator, and our continuing surveillance of installed equipment, improvement in this area will be apparent and m2asurable.
As noted by the NRC inspector at the exit interview or July 18, 1980, considerable improvement in housekeeping and protection of equipment has been achieved.
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