ML20063N951

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Responds to NRC Re Violations Noted in IE Insp on 820501-28.Corrective Actions:Subcontractor Procedures for Installation of Electrical Penetration Assemblies Submitted & Approved by Engineer
ML20063N951
Person / Time
Site: Washington Public Power Supply System
Issue date: 09/09/1982
From: Root R
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To: Bishop T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20063N944 List:
References
GO1-82-0550, GO1-82-550, NUDOCS 8210070387
Download: ML20063N951 (4)


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' f?(:?o Washington Public Power Supply Systerp.'

P.O. Box 968 3000 George Washington Way Richland. Washington 99352 1509),372 5000

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September 9, 1982 (,

G01-82-0550 Nuclear Regulatory h mission Region V 1450 ilaria Lane, Suite 210 Walnut Creek, California 94596 Attention: Mr. T. W. Bishop, Chief Reactor Construction, Projects Branch

Subject:

NUCLEAR PROJECT 1/4 NRC It'SPECTION WNP-1/4 DATES OF I'4SPECTION MAY l-28,1982 DOCKET N05. 50-460, 50-513 CONSTRUCTION PERMIT N'JS. CPPR-134, CPPR-174

Reference:

Letter TW Bishop to RW Root NRC Inspection at WHP-1/4 Site cated June 24, 1982 The above reference letter delineated the results of the May 1-28, 1982, inspection of activities authorized by NRC Construction Permit Nos. CPPR-134/174. Further, the referenced letter identified certain activities which were not conducted in full compliance with NRC requirements set forth in the Notice of Violation enclosed as Appendix A. This item of noncompliance has been categorized into a level as described in Supplement II of the Federal Register dated October 7, 1980 (45FR66754) as the Interim Enforcement Policy.

The specific finding, as identified, and the Supply System response is provided herewit.h as Appendix A.

R. W. Root Acting Program D ector JMS/by cc: CR Bryant, BPA (399)

JP Laspa, Bechtel (860)

V Mani, UE8C (897)

V Stello, Director of Inspection, NRC A Toth, NRC FDCC (899)

T'YA70387 821004 I !. J ADOCK 05000460 W_ PDR

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STATE OF WASHINGTON)

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COUNTY OF.BENTON ) .

R. W. Root, being first duly sworn, deposes and says: That he is the Acting Program Director, WNP-1/4, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authorized to submit the fore-going 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 7 , 1982 2dkL R. W/ Ro' /

On this day personally appeared before me R. W. ROOT 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 day of I Q _ , 1982 boHLAl &

Notary Publ/c in h for the State of Washington Residing at M /

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NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIA LANE, SUITE 210 WALNUT CREEK, CALIFORNIA 94596 DOCKET NO. 460 AND 50-513 CONSTRUCTION PERMIT NO. CPPR-134 AND -174 Appendix A A. 10 CFR 50 Appendix R Criterion V states, " 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. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." This is addressed in the WNP-1 Quality Assurance Program description in Section 17 paragraph 17.4.5 of the PSAR.

The electrical contractor's quality assurance manual, Chapter QAP-13 part 6.4, requires that, "Where special precautions are required for handling of items to prevent damage or other considerations, detailed instructions and/or procedures i shall be prepared and implemented." The contractor's implementing instructions 6 included the following requirements:

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a. Westinghouse installation procedure PEN-TR-48 which details tne installa- E.

tion of electrical penetration assemblies, including the installation of cable trays into the penetration sleeves prinr to insertion of the cables.

b. Foley-Wismer-Becker procedure OCP-7 part 4.7 which requires a process traveler for owner-furnished equipment, including hold points for quality inspection.
c. Foley-Wismer-Becker procedure QCP-10 which defines cable pulling criteria, including inspection for safe-edges and jacket condition.

Contrary to the above, on February 3, 1982 the electrical contractor (Foley-Wismer-Becker) subcontracted the installation of the electrical penetra-tion assemblies to the containment steel contractor (Pittsburg-DesMoines Corporation) without inclusion of appropriate installation procedures, includ-ing quality control inspection requirements for the electrical cable handling.

As a result, the following hardware discrepancies were identified on May 21, 1982, relating to installation activities conducted during the prior of March 2 through May 21, 1982:

a. In each case the cables had been installed into the penetration sleeves prior to insertion of the cable trays, inconsistent with the work sequence set forth in the Westinghouse instructions. The cable trays contained some sharp edges, such that the forcing of the trays into the sleeves under the heavy cable bundles could have resulted in abrasion and damage to the cable insulation jackets,
b. The completed installations of some cables, (including those for ~

penetrations HH4 and HJ4) resulted in the heavy cable bundles resting on the sharp edges of the pipe sleeves at the inside containment wall, with potential for long-term damage to the cable insulation jackets. (This matter has since been corrected by placement of cushion material under each such cable bundle.)

This is a Severity Level V Violation (Supplement II), applicable to Unit 1.

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SUPPLY SYSTEM REPON3E Corrective Action Taken The procedures developed by the subcontractor (PDM) for the installation of the Electrical Penetration Assemblies were submi',ted and approved by the Engineer (United Engineers & Constructors) and had been reviewed and signed by PDMs Authorized Nuclear Inspector (ANI).

The subcontractor's procedure outlined the use of the " Fabrication Check-list". This is a sequential description of the installation with hold points identified for signature. On June 14, 1982, hold points werc added to the PDM Fabrication Checklist (traveler) to assure that tray and cable installations receive Foley-Wismer & Becker (FWB) Quality Control inspection prior to and after t. ray and cable installation. The hold points established were to; check tray for sharp edges during tray insertion; cable is adequately protected and handled; before welding, cable is protected from heat and effects of welding; final installation acceptance (includes review for adequate cable protection after installation completion).

1-CNCR-218-1113 has been written to document those penetrations which had been previously installed without inprocess FWB QC inspections and for which cable had been draped over handrails and sharp edges. This CNCR will be submitted to UE8C for final disposition.

Corrective Action to Preclude Recurrence Westinghouse Installation Procedure, PEN-TR-76-48 was used to identify the steps required to install the Electrical Penetration Assemblies (CPA) prior to June 11, 1982. The Project did not* consider this vocedure to stipulate any specific sequential requirement for this process, i.e., tray installed prior to EPA or tray installed after EPA. On June 11, 1982, United Engineers & Constructors (UE&C) approved PCN-3A to FWB's QCP-10. This PCN describes how EPAs will be installed. This PCN allows the installation of EPAs either prior to or after the installation of the tray, Since this approved PCN provides for either method, the previous installations are acceptable.

In addition to the actions noted above, during future installation of EPAs, FWB will have a Quality Control Electrical In.cpector present during all phases of installation and handling and will document on Inspection Reports the required data outlined in the applicable QCPs.

Date of Full Compliance The actions to correct the above noted procedures and fabrication checklists have been completed. However, since the installation of Electrical Penetrations Assemblies have been discontinued due' to the extended construction delay at WNP-1, the effectiveness of the corrective actions taken can not be fully verified until construction resumes.

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