ML20003E012

Responds to NRC 810108 Ltr Re Violations Noted in IE Insp Repts 50-460/80-16 & 50-513/80-16.Corrective Actions:Sampled Vendor Drawings on Prepurchased & Site Contracts & Contractors Are No Longer Required to Ref Drawings

ML20003E012
Person / Time
Site:	Washington Public Power Supply System
Issue date:	02/03/1981
From:	Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20003E002	List: ML20003E006 ML20003E012
References
GO1-81-031, GO1-81-31, NUDOCS 8104020054
Download: ML20003E012 (14)

Text

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P. o. som ose sooo Geo. wasmwarom way Rientano. waswineroa. 99352 PMQNE (509) 375-5000 Nuclear Regulatory Commission February 3,1981 Region V G01-81-031 Suite 202, Walnut Creek Plaza 1990 fl. California Boulevard Walnut Creek, California 94596 '

Attention: Mr. G. S. Spencer e, C Chief Reactor Construction 'El fp9 _

and Engineering Support Branch ,

Gentlemen: / [

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Subject:

WPPSS NUCLEAR PROJECTS fl0S. 1/4 NRC IflSPECTI0fl - WNP-1/4 DATES OF INSPECTION - December 16 thru 19, 1980 DOCKET fl0S. 50-460 and 50-513 CONSTRUCTION PERMIT NOS. CPPR-134 and -174

Reference:

Letter from G. S. Spencer to R. L. Ferguson, NRC Inspection at WNP-1/4 Site, dated January 8,1981.

The referenced correspondence delineated the results of the December 16-19, 1980 inspection of activities authorized by NRC Construction Permits Nos. CPPR-134 and -174. Further, the referenced correspondence identified certain activities which were not conducted in full compliance with PSAR requirements set forth in the Notice of Violation enclosed as Appendix A.

These items of noncon.pliance have been categorized into a level as described in Supplement II of the Federal Register dated October 7, 1980 (45 FR 66754) as the Interim Enforcement Policy.

This letter is submitted in response to the referenced correspondence. Per telecon with Mr. D. Kirsch on February 2,1981 the due date for this response has been extended from February 1 to February 3, 1981. The specific finding (s), as identified, and the Supply System response is provided here-with as Appendix A.

Very truly yours, I

s l D. W Mc ur WNP-1/4 Program Director pm Enclosures cc: JR Lewis - Bonneville Power Administration CR Bryant - Bonneville Power Administration V. Mani - United Engineers & Constructors, Inc.

V. Stello - Director of Inspection and Enforcement-NRC 8104020 31-/~L

I Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596 Docket No. 50-460 Construction Permit No. CPPR-134 APPENDIX A Finding A As a result of the inspection conducted dLring the period December 16-19, 1980 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violations were identified:

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

. Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings..."

Section 1A, paragraph 11.2, of WPPSS quality class 1 nuclear-safety-related contract specification nos. 9779-23, 41, 62 and 113 states in part that "All contractor's drawings submitted shall be posted with the WPPSS Quality Class as designated in these documents and as called for on the Engineer's design drawings."

Contrary to the above requirement, as of December 17, 1980, (1) four contractor. drawings for specification 9779-23;(2) five contractor drawings for specification no. 9779-41; (3) three contractor drawings for specification no. 9779-62; and (4) six contractor drawings for specification no. 9779-113 were not posted with the~WPPSS quality class, as designated.

This is a repeat severity level IV violation (Supplement II of Federal Register Notice 45 FR 66754, dated October 7,1980).

. Supply System Response Corrective Action Taken' and Results Achieved A. Corrective Action Request Number CAR- H.0.-23 (Attachment 1) was issued to project engineering'on the nonconforming condition of vendor drawings not referencing the WPPSS Quality Class as required by the specifications.

In order to determine the extent of this nonconforming condition, project engineering and project QA sampled vendor drawings on many pre-purchased and site contracts. The results are summarized in Attachment #2. These results indicate that the majority of the pre-purchased vendors are not complying with the subject requirement and that the majority of the site contractors are complying. There are some exceptions to this sta*.o; as can be seen from the attachment.

. Appendix A Page Two (2)

The intent of the specification requirement to note the WPPSS quality class on vendor drawings was to assure that when a vendor translates project

. design drawings into his own installation or fabrication drawings, the I

quality class is maintained. This primarily affects site contractors, who generally prepare working drawings from project design drawings. Manu-facturers of equipment (off-site vendors) typically submit their own product drawings responsive to project specifications. Vendors control quality level by their own standard design controls and shop controls, such as indicating of code class, nuclear safety class, class IE, etc.

on the drawings or other controlling documents such as shop orders, travellers, etc. Therefore, imposing a requirement to add a specific WPPSS designation on manufacturer's drawings does not add any value to their control. The exception to this are those off-site vendors who translate project design drawings into subdrawings. These are:

o The vendors for pipi g sub assemblies (9779-123, 137 & 151 o The vendor for structural steel (9779-207)

Based on the above, the requirement to place the WPPSS quality class on drawings will be deleted on all- pre-purchased contracts except (9779-123, 137, 151 & 207). Those site contractors identified in Attachment #2 as not in full compliance will be required to correct any non-complying drawings. Corrective Actions Requests 1-CAR-216-03,1-CAS-246-10 'and 1-CAR-259-05 (Attachments #3, 4, & 5 respectively) have been initiated to obtain the required corrective action. Contract 9779-204 (Stainless Steel Liners) currently does not include this requirement but need not be revised, since all the work is quality class I.

Recognizing that this is a repeat violation, we have investigated the apparent breakdown in the implementation of our original corrective action to ascertain the cause of the continued deficiency.

As it turns out the problem is with the fact that we failed to adequately address which organization maintained responsibility for the site generated drawings versus pre-purchased- vendor documents. In keeping with this on May 4,1979 an interoffice memorandum was transmitted to Field Project Engineering from -the Field Project Engineering Manager stressing the need to verify the WPPSS Quality Class designation on the contractors' docum-entation. However, in doing so we neglected to close the loop with UE&C Engineering Philadelphia.concerning the pre-purchased documentation. This

.was an oversight on the' projects part; however, through site surveillances and the aforementioned corrective action requests, we have corrected the

. problem. In light of the confusion regarding this situation, all such future deficiencies associated with pre-purchased items will be discussed in detail with the UE&C Home Office.

Action Taken to Preclude Recurrence

After the specification revisions have been issued the pre-purchased-contractors with the few stated exceptions will no longer be required to reference the WPPSS quality class on their drawings.

m Appendix A Page Three (3)

Action Taken to Preclude Recurrence (Cont'd)

Satisfactory implementation and re-inspection of all stated corrective actions will result in acceptable drawings.

Date of Full Compliance It is anticipated that full compliance will be achieved by March 1,1981.

Appendix A Page Four (4)

Finding B B. 10 LFR 50, Appendix B, Criterion V, as implemented by Section 17.1.5 of the quali,ty assurance program documented in the PSAR and the WPPSS QA Progrbm Manual Procedure QAP-2, Paragraph 3.1 states, in part, that

" Activities affecting quality shall be prescribed by documented instru-ctions procedures and drawings, of a type appropriate to the circum-Stances and shall be accomplished in accordance with these instructions, procedures or drawings..."

Drawing no. 9779-LL-417652 for support no. CCW-54-SG-106, a WPPSS Quality Class 1, ASME III, Subsection NF Class 3 support in Section A-A depicts the shop welding configuration for the upper beam to wall attachment plate joint.

Contrary to the above, as of December 18, 1980, the as installed shop weld configuration for the upper beam to wall attachment plate joint did not conform to that specified by the drawing in that the joint configuration was rotated 180 from drawing orientation require-ment. The support was inspected and accepted by the material supplier on April 24, 1979.

This is a severity level IV violation (Supplement II of Federal Register Notice 45 FR 66754, dated October 7,1980).

Supply System Response B. An inspection of a larger population _(66 supports) of hanger supports has been performed by WPPSS/UE&C QA personnel to ascertain whether or not the subject condition could be considered an isolated case.

The inspection revealed that another three (3) supports exhibited similiar type joint orientation deficiencies.

The-additional findings are presently being evaluated by UE&C Engineering 'to determine the extent of required corrective actions.

These findings have been documented on WPPSS/UE&C Nonconformance Report 1-NCR-123-044.

A thorough corrective action plan-indicating the status of the as found conditions, corrective actions to prevent recurrence and 4

what reinspection actions may be required for the' installed supports will tre completed by March 2,1981. Therefore, to provide a more

'- . comprehensive report we request a thirty-day (3) extension for this response.

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STATE OF WASHINGTON COUNTY OF BENTON )

D. W. MAZUR, Being first duly sworn, deposes and says: That he is the Program Director, WNP-1/4, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authorized to submit the foregoing on behalf of said applicant; that he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge.

' DATED Z!3 , 1981 L

D N MA~

On this day personally appeared before me D. W. MAZUR to me known to be' the individual who executed the foregoing instrument and acknowledged that he signed the same as' his free act and deed for the uses and pur-poses therein mentioned.

GIVEN under my hand and seal this .3rd day of Vehmnvu ,1981

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~l "MDATE 17/30/90 CORReWWF"abriON ReOuesT WPPSS NUCLE AR PROJECTS PAGE I OF 3

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O NONCONFORh ING MATERI AL

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Project Engineering Manager

' DISCREPANCY IN PROCESS FROM:

QU ALITY ASSUR ANCE AUDIT G. Faust Project QAE (Field) O OTHER s-T NE A3vCR$E CONDITION DESCRIBEO 8ELOW R EQUIR ES IMM E DI AT E CORRECTIV E ACTION. PLE ASE INDICATE TH SIG N AND DATE COR P ECTIV E ACTION TO SE TAKE N IN $ PACE 18) SELOW, IN C L UD IN G THE IMPLEMENTA TNE C 0 4 RE C TIV E A C T ION STATEMENT AND RETURN T Mi$ FCRW to THE SENDER BY Al OESCRIPTION OF DISCREPANT CONDITION:

Reference Attachment NO. 1 .

RECOMMEND CORRE'TIVE ACTION: "

SIGN ATURE d P G A an OR PROJECT CAE B CORRECTIVE ACTION: ,

CAUSE AND ACTION TO BE T AKEN TO PREVENT RECURRENCE i CORRECTIVE ACTION ,

SIG N ATURE WILL BE IMPLEMENTED BY ( AODRE$$EE ) D AT E DATE C CONCURRENCE: ACCEPT / REJECT D ACTION VERIFIED: ACCEPT / REJECT COMMENTS COMMENTS i

G DATE PO AM OR PROJECT O AE DATE 2 PQ AM OR PROJECT QAE ,

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.-  ; iaTACHMENT I Page 2 of 3 I' ' CAR No. - H. O. 23 Attachment l' f's G * -

A. Descriction of Discrepant Condition

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During the NRC Inspection of 02/12/79, an " item of noncompliance was identified as follows:

Item of Noncomoliance Specification 9779-53, " Diesel Generators," in Paragraph 11.2, states that "All contractor's drawings submitted shall be posted with the WPPSS quality class as designated in 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 WPPSS quality class designation. These drawings were located in the UE&C drawing control files.

The supply systems' response to this finding was as follows: -

Action Taken to Correct the Identified Item The contractor has been advised that the majority of drawings submitted for the

@p") 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 WPPSS Quality Class. .

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

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 verification as to proper Quality Class of documents prior to issue. The directive also stated the importance of the WPPSS Quality Class to correctly note proper identification of equipment with respect to safety and operation of the Unit.

Date of Full Compliance ,

Full compliance achieved May 4, 1979. -

l The NRC performed a verification of corrective action to this item of non- *~

compliance during their inspection the week of 12/15-12/19/80. This verification confirmed that the committed corrective-action had been implemented. However, a.

random review of drawings on contracts 9779-23, 9779-418, 9779-41G, 9779-62 and 9779-113 by the NRC indicated that a similar condition exists on those contracts.

_G" The NRC concluded that the corrective action taken was ineffective and inadequate and stated that a repeat finding would be issued.

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j 6AR Nc.'. - H. 0. 23 Attachment 1 ATTACHMENT I Page 3'of 3 Page 2

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Recommended Corrective Action

1. . Review and evaluate vendor drawings to determine the extent of the nonconforming condition.

2. Provide a response indicating corrective action to be taken and

- include as-a minimum: .

'.i a.. . Corrective action .taken and results achieved,

b. Co'rrective action to preclude recurrence.

c. Date'of full compliance.

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. . ATTACHMENT 2 Page 1 of 2 f.peendim - 1 To utter UWP-81-095

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VFPSS Quality Class Ccn Description Included

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Partial Atmos. cicanup trains Yes 18 Fans & air handling units 22 Eberg. shutdown service Partial 23 vat 9r pt ps No Shop fab. tanks No 24A Haat exchsngero 26 No 273 Rad. Vaste nuclear air ccupressors No Ovarhead traveling cranes No 31 ASM3 auclear pu=ps No ~

35 Non-safety related chilled 39A water and susp pu=ps ASME III class 3 pv=ps Partial 393 ~fes ASM3 III valves 41BD Yes 4157 ASE III . valves Yes 41H ASMZ III valves Partial Pneum, cet. valves Partial 42A Pneum, act. valves 423 No .

Pneu=t. act, valves Partial 42C 42E Pneu:n. act. valves No 427 Pneum. act. valves No 5615KV evitchgear No

/*\ 47 4807 cctor control centers No

( / 43 Batteries, cbstgere 51 Pa.rtial Elect. penetrations Partial 55 58 Tecal instr. racks No ,,,

Pu=ps -

No 62 68 Cent.1so. valves Partial Compressor-condensing units Yes 72 Evaporative cooler units , , ,

No 174 Filters No

':76 A Misc. safety 5 relief valves ._ ~ ' No

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'91 D.C. switchgear 100 Distribution panels Partisi No

! 101 600V power & centrol cable No f

105 Instr. & special vire No 106 Emergency power sequencing S/S -

113 No

! Rad. monitoring systca Partial 121 130C Instrusantation No 130L Tank level instr. No -

Flow eiersents Yes 130I Transmitters No 131B Pressure switches Tes -

1313 1315 Thernal elemnts Partial 132 Flev el eants Yes i Shep Fsb. piping No 137 '

140 Missile shield Fo Hydrogen recombiners th 144 Elect. pancis 152

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• ATTACHMENT 2 Page 2 of 2 A$reediv. - 1 To Latter UE'dP-31-095 (ccot'd) h h*PPSS Qnn11ty Claas Condset No. Dascrioticu Includel 154 AS'G III piping specialties No Valves Partial 155 2C4 Stainicas steel liners so 207 Structural steel Yes NSSS piping & equip. install. Yes 211 Equip. hatch a personnel locks Yes 213 216 Eual installation Partial Electrical installation Yes .

218 219 Painting . H/ A Ho drswings req'd.

246 Underground piping- Partial Pield coatings N/A Mo drawings rg'd, 249 Spray pond pu=p house Yes 252 Main stes:2 iso. bldg. Yes 253 CSE superotructure Yes 234 Piping & cech. inseallstion Yes 257 '

Hajor rigging No 259 v

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ATTACHMEilT 3 Form 16-1-1

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H.O. N O @ WNP-1 s!TE NO.1-CAR-216:03 . CORRECTIVE ACTION REQUEST g wNp .4 oATE 1/30/81 WPPSS NUCLE AR PROJECTS PAGE 1 OF 1 O NONCONFORMING MATERI AL University Mechanical .

NCR Attention: Don Larsen, QA Manager O DISCREPANCY IN PROCESS FROM: '

T. J. HouChins Project QA Manager O OuAtiTy ASSURANCE AuoiT h OTHER Spec. Requirement T HE ADV E RSE CON 0lfl0N DES CRIS ED S EL0w R EQUIR ES isd M EDIAT E CORRECTIV E ACTION. PLE ASE IN0lCATE THE C AUSE AND CORRECTIVE ACTION TO SE TAKEN IN SPACE (8) SELOW, IN C L UD ING THE sMPLEMENT T 0 . SIG N AND DATE THE CORRECTIVE ACTION STATEMENT AND RETURN THIS FOR M TO THE SENDER SY /

j DESCRIPTION OF DISCREPANT CONDITION:

Paragraph 25.2 of Section lA of specification 9779.216 requires that all contractor drawings submitted shall be posted with the WPPSS Quality Class.

Contrary to this requirement, a review of contractor drawings submitted to date indicates many of your drawings do not meet this requirement.

RECOMMEND CORRECTIVE ACTION:

Immediately review the latest revision of all drawings submitted to the Engineer to assess compliance with the above requirement. Update and resubmit drawings as required.

(SIGNATURE [

' PQAM OR PROJECT 4 AE NM B CORRECTIVE ACTION:

CAUsE AND ACTION TO BE TAKEN TO PREVENT RECURRENCE CORRECTIVE ACTION WILL BE IMPLEMENTED BY stGN ATURE DATE (ADORESSEE) DATE C CONCURRENCE: ACCEPT / REJECT D ACTION VERIFIED: ACCEPT / REJECT COMMENTS COMMENTS

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$ PQAM OR PROJECT QAE DATE POAM oR PROJECT O AE DATE i

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ATTACHMENT 4 Form 16-1-1 mited engineers u-c

" E]DNP-1 E No. 1-CAR-246-10 CORRECTIVE ACTION REQUEST 3 eNp -4 oATE 1/du/dl WPPSS NUCLE AR PROJECTS pAoE l or I NONCONFORMING MATERI AL Peter V,iewit & Sons NCR Attention: 1(en Bedell, QA Manager O otSCREPANCY IN PROCESS FRoM: '

oUALITY ASSUR ANCE AUDIT T. J. Houchins, Project QA Manager y oTHER Rnor - Donniromont THE A0wtRSE CON 0lfl0N DESCRISED SELOW R E Q UIR ES IMMEO,l ATE COR RECTIVE AC flON. PLE ASE INQlCATE THE C AUSE AND CO R R ECTIV E ACTION TO SC TAKEN IN SPACE ( S) SELow. INCLUDING D . SIG N AND Q ATE THE CORRECTIVE ACTf 0N STATEMENT AND RETURN THIS FOR M TO THETHE IM ASYLEME SENDER NT Ah10NO /09/NT .

j DESCRIPTION OF DISCREPANT CONDITION:

Paragraph 25.2 of Section lA of specification 9779.245 requires that all contractor drawings submitted shall be posted with the WPPSS Quality Class.

Contrary .o this requirement, a review of contractor drawings submitted to date indicates many of your drawings do not meet this requirement.

RECOMMEND CORRECTIVE ACTION:

Immediately review the latest revision of all drawings submitted to the Engineer to assess compliance with the above requirement. Update and resubmit drawings'as required.

cQ SIGN ATURE [

• d MM Ob *QAM OR PROJECT Jat B CORRECTIVE ACTION:

CAUSE ANo ACTION To BE TAKEN To PREVENT RECURRENCE CORRECTIVE ACTICN

• WILL BE IMPLEMENTED BY SIGNATURE OATE (AODRESSEE) OATE

, C CONCURRENCE: ACCEPT / REJECT D ACTION VERIFIED: ACCEPT / REJECT COMMENTS COMMENTS oATE PQ AM oR PROJECT Q AE oATE I 3 POAM oR PROJECT QAE I

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ATTACHMENT 5 H.o. N o

. inited engineers A_m Form 16-1-1

lit no.1-CAR-259-05 h WNP-1 CORRECTIVE ACTION REQUEST g wNP 4 DATE. 1/30/81 -

WPPSS NUCLE AR PROJECTS pAoE_1 or 1 To ( Addressee):

Lampson O NoNCoNPoRMING MATERIAL Attention: Bob Knight, Project Manager NCR em ,

olSCREPANCY IN PROCESS T. J. Houchins, Project QA Manager O oVAllTY ASSURANCE AUDIT O oTHER.__Soec. Recuirement THE ADVERSE CONDITION DESCRISCO 8tL0w REQUIRES IMME3, LATE CCRRECTIVE ACTION.

PLEASE INDICATE THE CAUSE AND CoR R ECTIV E ACTION TO SE TAK E N (M $ PACE (3) B E LO W, IN C L UDIN G THE IMPL EMEN TA THE CCRRECTIVE ACTION S TATE M E N T AND RETURN THIS FCR M02/09/81 TO T H E SENCER SV A l DESCRIPTION OF DISCREPANT CONDITION:

Paragraph 25.2 of Section l A of specification 9779.259 requires that all '

contractor drawings submitted shall be posted with the WPPSS Quality Class.

Contrary to this requirement, a review of contractor drawings submitted ~

to date indicates many of your drawings do not meet this requirement.

RECOMMEND CORRECTIVE ACTION:

Immediately review the latest revision of all drawings submitted to the Engineer to assess compliance with the above requirement. Update and resubmit drawings as required.

8 CORRECTIVE ACTION:

sk SIG N ATUR P...W JM_!.s 7.[M

._ .E CAUSE ANo ACTION TO BE TAKEN To PREVENT RECURRENCE l

l CORRECTIVE ACTION WILL BE IMPLEMENTED BY SIGNATURE QATE (A00RESSEE) DATE C CONCURRENCE: ACCEPT / REJECT D ACTION VERIFIED: ACCEPT / REJECT COMMENTS COMMENTS 2 PoAM CR PROJECT oAE DATE Po AM CR PROJECT o AE DATE s